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Internal Revenue Code (IRC) Tax Rates

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman David Schweikert, R-AZ

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy and political debates in Congress. In this episode of “The Cloakroom with...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman Brendan Boyle, D-PA

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy debates in Congress. In this episode of “The Cloakroom with Peter Roskam,”...more

Foster Garvey PC

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

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In the S corporation arena, tax advisors generally do not focus much attention on unreasonable compensation. As we delve into the issue in this Part VII of my multi-part series on Subchapter S, it will become apparent that...more

ASKramer Law

Taxation of Foreign Currency Transactions Part II: Gains, Losses, Personal Transactions, and Electing Out of Section 988

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Are all foreign currency gains taxable? No. Under a de minimis exemption individual taxpayers with foreign currency gains of $200 or less on a “personal transaction” do not need to report them....more

DarrowEverett LLP

Maximizing QSBS Benefits with Estate Planning: The Art of Stacking

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The number of taxpayers seeking the benefits of Qualified Small Business Stock (“QSBS”) has picked up steam in recent years, particularly since the Tax Cuts and Jobs Act (“TCJA”) lowered the federal corporate tax rates to...more

ASKramer Law

Taxation of Foreign Currency Transactions Part I: Definitions and Rules for Taxing Foreign Currencies

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Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more

DarrowEverett LLP

Accidental Termination on Purpose? S Corp Ruling Could Be Huge For QSBS Owners

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Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...more

McDermott Will & Emery

TTB Ramps Up Tax Audits and Enforcement

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The Alcohol and Tobacco Tax and Trade Bureau’s (TTB) Office of Field Operations is responsible for ensuring industry members comply with the Federal Alcohol Administration Act, the Internal Revenue Code and all related...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part II – Code...

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This second installment of my multi-part series on Subchapter S is focused on two Code Sections, namely IRC Section 1375 and IRC Section 1362(d)(3)....more

Rivkin Radler LLP

Nothing Lasts Forever –Expiring Tax Provisions

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The Long-Term View- Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole. ...more

Allen Barron, Inc.

The High IRS Tax Rates on a Foreign Trust

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Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more

Holland & Knight LLP

Condemned to Lose Your ADIT?

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In a private letter ruling, the IRS concluded that the condemnation of public utility property is in effect a "retirement" or "disposition" that requires the elimination of accumulated deferred income taxes (ADIT) associated...more

Goulston & Storrs PC

Biden’s FY2024 Budget: Key Real Estate Tax Proposals

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On March 9, 2023, President Biden released his FY2024 budget (the “FY2024 Budget”), and the U.S. Treasury released the so-called “Green Book," which provides details related to the revenue provisions in the FY2024 Budget....more

Pierce Atwood LLP

2023 Federal and State Estate and Gift Tax Summary

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Estate and gift taxes are levied on transfers of property during lifetime and at death. The federal government and many state governments impose such taxes and adjust the amounts subject to tax annually for inflation (or...more

Burr & Forman

Changes in Tax Rates for 2023

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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

McDermott Will & Emery

Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

Cadwalader, Wickersham & Taft LLP

Looking Forward: The IRS Denies 40/60 Treatment for Over-the-Counter Foreign Currency Options under the Mark-to-Market Rules

The IRS has published Proposed Regulations clarifying that for purposes of the mark-to-market rules under section 1256, foreign currency contracts include only foreign currency forward contracts, and that the definition does...more

Groom Law Group, Chartered

Administration Budget Proposals Tighten Rules for 409A Violations, VEBA Funding and Indemnity Health Plans

On March 28, the Biden Administration submitted its Fiscal Year 2023 budget proposals reflecting its budget and tax policy priorities, which could surface when Congress resumes work on budget reconciliation. While it is...more

Freeman Law

Tax Treaty-Based Return Reporting Disclosures

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A taxpayer taking a treaty-based return position is generally required to disclose that position, unless an exception applies. A treaty-based return position is a tax reporting position, maintaining that a U.S. tax treaty...more

Foster Garvey PC

The Build Back Better Act Was Passed in the House and Is Now in the Senate

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On November 19, 2021, HR 5376, the 2,476-page bill, commonly known as the Build Back Better Act, was passed by the U.S. House of Representatives by a vote of 220-213. The House’s vote on HR 5376 was held after the...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

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...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Freeman Law

Congress Readies New Round of Tax Increases

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The House Committee of Ways and Means (the “House”) has been busy the last few days. Indeed, the House continues to mark up and work through potential revenue raisers (i.e., tax increases) to help pay for recent legislative...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposal on Domestic Businesses

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On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more

Proskauer Rose LLP

Let the Estate Tax Planning Games Begin - But Where Will They Land - the House Ways and Committee Has Spoken

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“President Biden and Democrats in the Congress have been working on a $3.5 trillion spending and tax package, and the details are starting to be revealed. Indeed, on Sunday, September 12th, the House Ways and Means Committee...more

Gray Reed

Carried Interest Taxation: Update on Final Regulations and Potential Legislative Changes

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In January 2021, the U.S. Department of Treasury and the Internal Revenue Service  released final regulations (the Final Regulations) under Section 1061 of the Internal Revenue Code of 1986, as amended (the Code).  Code...more

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