Public M&A Day in Frankfurt
Fintech Focus Podcast | Are Regulators Dictating Fintech Deal Terms?
Business Better Podcast Episode: Strategic Partnership and Company-Building Investments – A Conversation with Prairie Capital
JONES DAY TALKS®: Corporate Venture Capital: Market Overview, Trends in Deal Terms, and Special Considerations
Business Better Podcast Episode: Investing in the New Mainstream Economy - A Conversation with Palladium Equity Partners
Healthcare Investments: Analyzing the Surge in Infusion Centers
Electricity Markets: A Regional Perspective
PODCAST: Williams Mullen's Benefits Companion - Exploring the Value of Qualified Default Investment Alternatives
Hot Topic: UPMIFA in the Context of Financial System Instability
5 Key Takeaways | The U.S. Investment in Clean Energy and the Potential for Supply Chain Snags
Consumer Finance Monitor Podcast Episode: A Primer on “Dark Patterns,” with Special Guest Andrew Nigrinis, PhD, Managing Principal, Edgeworth Economics
Stoel Rives | Deeply Rooted Podcast S2E4: S2E4: Skye Root, Founder of Root Agricultural Advisory
Legal Alert | DOL Opens ESG Door: What Does It Mean for Plan Fiduciaries?
Nota Bene Episode 27: The Gangbuster State of Private Equity and Merger and Acquisition Cycles in the U.S. with Luca Salvi
Value-based health care: private equity investors
Health care M&A
I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...more
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
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
On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more
On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more
Since 2019, Form 1040 has included a general question regarding the taxpayer’s cryptocurrency activity. Over the years, the IRS has modified the scope of its cryptocurrency inquiry. On the 2021 Form 1040, this question read:...more
The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...more
The cryptocurrency industry may be breathing a sigh of relief following the release of recent IRS guidance on cryptocurrency tax reporting, which effectively postpones the January 1, 2023 effective date of the digital asset...more
Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 12, 2022 – September 16, 2022...more
Cryptocurrency holders often want to put their assets into an entity for a host of reasons, such as asset protection, arranging negotiated management rights and exit planning. This post discusses basic federal income tax...more
On February 11, 2022, in a letter addressed to certain U.S. Senators, the U.S. Department of the Treasury indicated that cryptocurrency miners, cryptocurrency stakers or related hardware or software providers would not be...more
As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more
Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more
As we recently noted in our OnPoint dated October 20, 2021, the rise in interest from retail and institutional investors in the cryptocurrency market has attracted increased regulatory and enforcement attention in the past...more
I Predicted the Subprime Lending Bubble’s Collapse. The Signs Are The Same For Crypto. When I predicted the bursting of the housing market’s subprime lending bubble in 2006, a lot of people called me crazy....more
Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more
If you’ve engaged in cryptocurrency or other virtual currency transactions worth $20,000 in any one year between 2016 and 2020, the IRS wants to hear from you. The IRS believes thousands of taxpayers are not telling the...more
On July 31, 2020, the IRS and Treasury issued proposed regulations under section 1061 of the tax code. Section 1061 imposes a three-year holding period as a precondition to recognizing long-term capital gains on carried...more
Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more
In light of the disruption of business activities this year and the economic uncertainty created by the ongoing COVID-19 pandemic, the Internal Revenue Service (IRS) issued Notice 2020-39 (the IRS Notice) on June 4, 2020,...more
Introduction - Gain of a fund or other investment partnership from a capital asset sale held for over one year is taxed to the fund’s partners at favorable long-term capital gains rates. Until 2018, this general rule...more
On October 9th, the Internal Revenue Service released Private Letter Ruling 202041009 (the “Ruling”), which, in what many in the nonprofit community would have expected to be a relatively straight-forward exemption approval...more
What many in the nonprofit community would have expected to be a direct road for tax exemption for a new 501(c)(3) nonprofit organization has suffered a significant set-back. On October 9th, the Internal Revenue Service...more