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Income Taxes › Tax Planning › Capital Gains

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Morgan Lewis

UK Government Updates Tax Regime for Carried Interest

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As part of the Autumn Statement, the UK government on 30 October 2024 announced a reform of its taxation of carried interest. This follows a call for evidence on the reform of the UK taxation treatment of carried interest in...more

Cadwalader, Wickersham & Taft LLP

The UK Government’s Autumn Budget 2024

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The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2024 on 30 October 2024. The Budget was the first to be delivered by the new Chancellor of the Exchequer, following the election of the Labour...more

Weber Gallagher Simpson Stapleton Fires &...

Navigating Tax Changes in 2025: A Guide for Separating Couples

Weber Gallagher Simpson Stapleton Fires &... on

As the election approaches, discussions regarding tax modifications and changes to the tax law have increased. But before the election, the IRS has already announced some new IRS regulations which will begin in 2025. As...more

Cadwalader, Wickersham & Taft LLP

First Stand-Alone Crypto Tax Fraud Case Leads to Guilty Plea

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On September 12, 2024, the U.S. Department of Justice (“DOJ”) announced that Frank Richard Ahlgren III pleaded guilty to filing a false tax return underreporting gains from selling $3.7 million in Bitcoin. As we discussed...more

Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

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In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

ASKramer Law

Business Taxation of Hedging Transactions Part V: Consolidated Groups

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Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more

Proskauer - Tax Talks

Change to non-domicile tax regime forms part of UK Spring Budget 2024

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As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more

Adler Pollock & Sheehan P.C.

It’s Time to Take Another Look at the Stepped-Up Basis Rules

Adler Pollock & Sheehan P.C. on

Thanks to a generous federal gift and estate tax exemption amount ($13.61 million for 2024), only the wealthiest of families are exposed to estate tax liability. For many, this means that estate planning now has a stronger...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The ManyTraps That Exist For The Unwary: Part I – The...

Foster Garvey PC on

In October 2023, I authored a new White Paper, A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary. This year, in a multi-part article, I intend to take our blog...more

Rivkin Radler LLP

Taxes and the 2024 Election: ‘Tis the Season to Plan and Act

Rivkin Radler LLP on

This is The End- I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...more

ASKramer Law

Hedging: Inadvertent Errors and Tax Identification

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Businesses often manage their price risks by hedging those risks with financial derivative contracts. Because businesses generate ordinary income and loss on their normal business activities, they want to be sure their...more

Gray Reed

Phantom Income: The Spooky Side of Taxation

Gray Reed on

There’s a hidden tax horror behind pass-through entities, cancellation of debt, and even prizes, winning, and awards: “phantom income.” It even sounds scary, right? And when it comes to one’s tax liability, it can be...more

Troutman Pepper

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

Troutman Pepper on

In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more

Nutter McClennen & Fish LLP

Estate and Income Tax Provisions in Pending Massachusetts Tax Relief Package

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The Massachusetts House and Senate voted in favor of a Massachusetts tax relief bill. The legislation is now on Governor Maura Healey’s desk, and she has until October 8th to act. More than two decades have passed since the...more

Harris Beach PLLC

Massachusetts Unveils New Tax Relief

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On September 26, 2023, Massachusetts leaders announced major tax legislation that includes estate tax relief, closing a loophole around the newly implemented millionaire’s tax, short-term capital gains tax cuts and more. It...more

WilmerHale

State Taxation of Qualified Small Business Stock: Federal Tax Exclusion Not Always Replicated at State Level

WilmerHale on

In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more

Harris Beach PLLC

Massachusetts Tax Law Update - May 2023

Harris Beach PLLC on

On April 13, the Massachusetts House of Representatives approved H.3770, a tax reform bill that includes significant changes for individuals, businesses and estates. The bill is now with the Senate’s Ways and Means Committee,...more

Miller Nash LLP

Washington’s New Capital Gains Excise Tax: An Income Tax by Another Name

Miller Nash LLP on

The Washington State Supreme Court recently upheld an excise tax on the privilege of selling capital assets within the State of Washington. The Court upheld the new tax over concerns that the tax violated both the state and...more

Cadwalader, Wickersham & Taft LLP

IRS Sheds Light on Harvesting Crypto Losses

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Some investors who experienced rapid declines in the value of their cryptocurrencies during 2022 may be attempting to claim 2022 tax losses. According to the IRS’s Office of Chief Counsel, some of these investors may be out...more

Morgan Lewis

Planning for the Massachusetts ‘Millionaires Tax’

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The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more

Burr & Forman

Changes in Tax Rates for 2023

Burr & Forman on

The IRS has issued Revenue Procedure 2022-38, which sets forth inflation-adjusted items for various provisions of the Internal Revenue Code which will be applicable in 2023. Here are some of the highlights...more

Katten Muchin Rosenman LLP

Greener Pastures: Five Things to Consider When Leaving One Jurisdiction for Another

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Is the grass always greener on the other side? Like any major life decision, deciding to uproot yourself (and potentially your family) and move from one state to another is not an easy decision. Although laws, taxes and...more

Greenberg Glusker LLP

Harry Potter and the Chamber of Secret QSBS Exclusions

Greenberg Glusker LLP on

Are your shareholders leaving money on the table? Certain tax planning strategies, much like magic spells in the Wizarding World of Harry Potter, require some pre-ordained incantations in order to bring them to life. The...more

Cadwalader, Wickersham & Taft LLP

Mini-Me Crypto Tax Legislation

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Bipartisan crypto legislation was introduced by Senators Pat Toomey (R-PA) and Kyrsten Sinema (D-AZ) on July 26, 2022. If enacted, the Virtual Currency Tax Fairness Act would exclude from gross income gain on certain de...more

Tucker Arensberg, P.C.

PA Welcomes 1031 Tax Deferred Exchanges

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Many real estate investors in Pennsylvania have had an unpleasant surprise when they learn that the Commonwealth has never recognized the 1031 Tax deferred exchanges for Pennsylvania income tax purposes. After years of...more

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