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Seward & Kissel LLP

Final Tax Rules and Transitional Guidance for Broker Reporting

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The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more

Seward & Kissel LLP

August 30 Deadline for TIC Form SHL

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Memorandum to our Investment Management Clients and Friends - The Quinquennial Report of Foreign-Resident Holdings of U.S. Securities (“TIC Form SHL”) is a benchmark report used by the U.S. Department of the Treasury to...more

Mintz - Securities & Capital Markets...

Proposed Treasury Regulations Provide Guidance on Stock Buyback Excise Tax for Redemptions and M&A Transactions

On April 12, 2024, the Treasury Department and Internal Revenue Service (IRS) issued proposed Treasury Regulations (REG-115710-22) providing comprehensive guidance for applying the one-percent excise tax owed on corporate...more

Proskauer - Tax Talks

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

Proskauer - Tax Talks on

On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more

Holland & Knight LLP

Not So Cryptic: IRS Increases Oversight on Cryptocurrency Income Tax Reporting Requirements

Holland & Knight LLP on

Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued last year, the IRS recently increased its oversight of cryptocurrency...more

Sheppard Mullin Richter & Hampton LLP

CMS Issues CY2025 Medicare Advantage and Part D Final Rule

On April 4, 2024, the Centers for Medicare & Medicaid Services (“CMS”) issued the contract year 2025 (CY2025) Medicare Advantage and Part D final rule (the “Final Rule”). In addition to finalizing its CY2025 proposed rule,...more

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

Rivkin Radler LLP on

Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

Pillsbury Winthrop Shaw Pittman LLP

New Digital Asset Regulations Provide Glimmers of Much-Needed Clarity

The proposed regulations under the Infrastructure Investment and Jobs Act (IIJA) expand the definition of “broker” to include anyone who provides facilitative services which effectuate sales. Not surprisingly, centralized...more

Cadwalader, Wickersham & Taft LLP

IRS Holds That Crypto Staking Rewards are Taxable Income

The Internal Revenue Service (“IRS”) recently issued guidance in Revenue Ruling 2023-14, holding that taxpayers who stake their cryptocurrency and receive additional units of cryptocurrency as rewards when validation occurs...more

ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules – Part 1

ArentFox Schiff on

Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more

McDermott Will & Emery

IRS Releases Proposed Regulations Addressing Repatriations of Intangible Property

McDermott Will & Emery on

BACKGROUND: SECTION 367(D) Section 367(d) generally addresses outbound transfers of intangible property to a foreign corporation. It treats a US transferor that transfers intangible property subject to Section 367(d) as...more

Snell & Wilmer

Taxation of Cryptocurrency and Similar Transactions

Snell & Wilmer on

Whether you’re an investor expanding your portfolio to include digital assets such as cryptocurrencies and tokens, a business that uses cryptocurrencies to engage in everyday transactions, or a crypto “miner," you need to...more

McDermott Will & Emery

NFTs and Charitable Fundraising: Navigating Tax Hurdles

McDermott Will & Emery on

As the creation of and transactions involving non-fungible tokens (NFTs) have increased dramatically, so has interest in using NFTs as donations to charitable organizations and for other charitable fundraising tools. Given...more

Opportune LLP

Valuation Perspective: Top 3 Topics Energy Companies Should Consider At Year-End

Opportune LLP on

Here are three valuation topics energy companies should consider as they plan their year-end meetings....more

McDermott Will & Emery

Special Report - A Primer on Charitable Contributions of Virtual Currency

McDermott Will & Emery on

The explosive growth in virtual currency (also referred to as cryptocurrency, digital assets, tokens and digital currency) is evidence of increasing popularity and acceptance of it as a new investment asset class. With the...more

Pillsbury Winthrop Shaw Pittman LLP

SEC Moves to Modernize Framework for Securities Offerings and Sales to Workers

The SEC takes a highly anticipated first step toward updating Rule 701 and Form S-8 - Amendments to Rule 701 would increase the cap on exempt offerings and ease disclosure burdens. Revisions to Form S-8 would permit...more

A&O Shearman

IRS Issues Virtual Currency Tax Guidance on Forks and Airdrops

A&O Shearman on

On October 9, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Ruling 2019-24 (the “Revenue Ruling”) and questions and answers (the “Q&A” and, together with the Revenue Ruling, the “Guidance”) addressing certain...more

Burr & Forman

Cryptocurrency Tax Guidance Expected Soon

Burr & Forman on

The Internal Revenue Service (“IRS”) will be releasing guidance on the tax treatment and reporting requirements of “virtual currencies” (i.e., cryptocurrencies) very soon, according to Internal Revenue Service Commissioner...more

Adler Pollock & Sheehan P.C.

Insight on Estate Planning - February/March 2019: Basis consistency rules come into play when inheriting property

If a person is in line to inherit property from a parent or other loved one, it’s critical to understand the basis consistency rules. Tax law provides that the income tax basis of property received from a deceased person...more

Foodman CPAs & Advisors

Lo que sabemos sobre el Cumplimiento Crypto y los impuestos federales de los EE. UU.

La última Notificación emitida por el IRS sobre Criptomoneda fue el Aviso 2014-21 publicado el 25 de Marzo del 2014 que brinda orientación en forma de respuestas a preguntas frecuentes (“Frequently Asked Questions”). ...more

Snell & Wilmer

Taxation of Virtual Currency Transactions

Snell & Wilmer on

With the use of virtual currency on the rise, questions emerge as to how virtual currency transactions are taxed. The IRS has issued guidance regarding the tax consequences of such transactions, answering some questions but...more

Foodman CPAs & Advisors

Many are now looking for IRS Guidance on Virtual Currency

Foodman CPAs & Advisors on

Due to its unprecedented level of value appreciation, Bitcoin investors, consumers and businesses are looking for IRS Guidance. IRS recognizes that “virtual currency” may be used to pay for goods or services, or be held for...more

Proskauer - Tax Talks

IRS Proposed Regulations Under Section 305(c)

Proskauer - Tax Talks on

In April, the IRS issued proposed regulations interpreting deemed distributions under Section 305(c). Specifically, the proposed regulations would clarify the amount and timing of deemed distributions that result from an...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Orrick, Herrington & Sutcliffe LLP

Annual ISO and ESPP Information and Reporting Requirements

Annual Information Statements and IRS Returns - Requirement to Report - For any exercise of an incentive stock option (ISO) or transfer of a share previously purchased pursuant to a tax-qualified employee stock...more

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