News & Analysis as of

Tax Liability Proposed Regulation Tax Reform

Cadwalader, Wickersham & Taft LLP

Proposed Regulations for Buyback Tax Hit LBOs, Preferred Stock but Spare Tier 1 Capital

The government released proposed regulations this month implementing the excise tax imposed on repurchases of corporate stock that was enacted in 2022.  Although these regulations provide some welcome clarity as to the scope...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Gray Reed

IRS Characterizes Monetized Installment Sales as Listed Transaction in Proposed Regulations

Gray Reed on

Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time.  On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more

Cadwalader, Wickersham & Taft LLP

Airing Dirty Laundry: Biden Budget Targets Crypto Wash Sales

Last year the Biden Administration’s crypto tax proposals contained some helpful clarifications, including endorsing non-recognition treatment for crypto lending, together with measures aimed at gaining insight into the...more

Cadwalader, Wickersham & Taft LLP

Proposed Treasury Regulations Would Disallow Technique to Reduce Subpart F and GILTI Inclusions

On December 9, 2022, Treasury released proposed regulations that would prevent consolidated groups from engaging in certain related party transactions to reduce the group’s Subpart F and GILTI inclusions. Specifically,...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Proskauer Rose LLP

UK Tax Round Up - December 2021

Proskauer Rose LLP on

UK Case Law Developments - Taxpayer treated as receiving distribution in tax avoidance case - We reported on First-tier Tribunal’s (FTT’s) decision in Dunsby v Revenue & Customs in our June 2020 UK Tax Round Up. By way...more

Holland & Knight LLP

Colombia Propone Cambios a las Regulaciones Tributarias - Una Mirada a los Principales Cambios Propuestos por la Ley de...

Holland & Knight LLP on

En términos generales, los cambios impositivos propuestos más grandes de Colombia tendrían un impacto en el Impuesto sobre las ventas (IVA), la creación de un impuesto unificado denominado SIMPLE, la emisión del impuesto a la...more

Burr & Forman

The New Section 199A 20% Profit Deduction for Pass-Through Businesses: A Case Study: Court Reporters

Burr & Forman on

Congress enacted the new Section 199A 20% profit deduction for the owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain trusts. Section 199A is intended...more

Goodwin

Year-End Tax Planning, Tax Reform and Proposed 2704 Regulations Withdrawn

Goodwin on

With the end of year approaching, now is the time to consider making gifts to lower your federal and state estate tax liability. That tax liability, however, could change with impending federal tax reform. Regardless of the...more

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