News & Analysis as of

Tax Deductions Internal Revenue Code (IRC)

McDermott Will & Emery

Weekly IRS Roundup August 26 – August 30, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26, 2024 – August 30, 2024. ...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – August 23, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19, 2024 – August 23, 2024. August 19, 2024: The IRS released Internal Revenue Bulletin...more

Cadwalader, Wickersham & Taft LLP

Liberty Global Appeals Economic Substance Doctrine Ruling

In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more

Rivkin Radler LLP

Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again

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There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more

McGlinchey Stafford

Impacts of Cannabis Rescheduling on Bankruptcy

McGlinchey Stafford on

Despite the excitement of many over rescheduling cannabis from Schedule I to Schedule III, the move does not make cannabis “legal” unless it is produced, sold, and used within the tightly regulated parameters of the...more

McDermott Will & Emery

Weekly IRS Roundup July 22 – July 26, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 22, 2024 – July 26, 2024....more

McDermott Will & Emery

Weekly IRS Roundup July 1 – July 5, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 1, 2024 – July 5, 2024....more

Holland & Knight LLP

A Look at IRA Prevailing Wage and Apprenticeship Requirements Final Regulations Highlights

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The U.S. Department of the Treasury and IRS on June 25, 2024, issued final regulations regarding increased credit or deduction amounts available for taxpayers satisfying prevailing wage and registered apprenticeship...more

McDermott Will & Emery

Weekly IRS Roundup June 17 – June 21, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17, 2024 – June 21, 2024. ...more

McDermott Will & Emery

Weekly IRS Roundup June 10 – June 14, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 10, 2024 – June 14, 2024....more

McDermott Will & Emery

Weekly IRS Roundup May 27 – May 31, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 27, 2024 – May 31, 2024. ...more

McGlinchey Stafford

Paid or Incurred: Marijuana Rescheduling, Taxes, and Section 280E

McGlinchey Stafford on

The cannabis industry knows well the economic burden imposed by Section 280E of the Internal Revenue Code of 1986 (Code). It substantially increases the cost of doing business because it disallows deductions for expenses...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

Mintz

Rescheduling Madness: Key Takeaways from the Proposed Rule to Reschedule Marijuana under the CSA

Mintz on

Moving marijuana under the Controlled Substances Act (“CSA”) from Schedule I to Schedule III will bring celebrated changes to the beleaguered state-sanctioned cannabis industries currently operating in 37 states, but will...more

Cadwalader, Wickersham & Taft LLP

Getting Technical with Partnership Termination Rule

The Tax Court recently ruled that a new partnership (“New Shoals”) that is deemed to form on a technical termination may use a taxable year that starts on the date of the termination of the old partnership (“Old Shoals”),...more

Polsinelli

Tax Court Strikes out Smoltz and Klesko’s Big K SCE, but Provides Relief for Those Facing Fraud Allegations

Polsinelli on

In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more

ASKramer Law

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

ASKramer Law on

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

McDermott Will & Emery

Weekly IRS Roundup May 6 – May 10, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6, 2024 – May 10, 2024. ...more

Cole Schotz

Weed it and Reap: Cannabis Rescheduling’s Impact on Tax Deductions

Cole Schotz on

As the state legalization of medicinal and adult-use cannabis spreads across the United States, cannabis producers and retailers are experiencing a rapid increase in production and sales. However, despite this boom in...more

McDermott Will & Emery

Weekly IRS Roundup April 29 – May 3, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 29, 2024 – May 3, 2024. ...more

McDermott Will & Emery

Weekly IRS Roundup April 22 – April 26, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 22, 2024 – April 26, 2024. ...more

Saul Ewing LLP

Non-Profits May Benefit From Energy-Efficient Construction/Renovation Under Inflation Reduction Act Expansion of IRC § 179D

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Section 179D of the Internal Revenue Code, first enacted in 2006, grants qualifying building owners or tenants of commercial buildings a federal tax deduction for the installation of energy-efficient features and systems in...more

McDermott Will & Emery

Weekly IRS Roundup April 15 – April 19, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 15, 2024 – April 19, 2024. ...more

Carlton Fields

Tax Court Upholds IRS Decision That Premiums Paid to Microcaptive Insurance Companies Did Not Qualify for Tax Deductions

Carlton Fields on

The U.S. Tax Court recently upheld a determination by the IRS that premium payments to certain microcaptives could not be deducted for tax purposes because the premium payments were not actually for “insurance.”...more

Polsinelli

Easement Fund Victory on Perpetuity Will Result in More Attention on Valuation

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In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more

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