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Tax Liability Regulatory Agenda

Cadwalader, Wickersham & Taft LLP

Presidential Candidates’ Tax Proposals Diverge on the Road to November

The outcome of the upcoming elections is likely to significantly impact future tax legislation.  Notably, many tax provisions enacted under prior tax legislation, commonly called the Tax Cuts and Jobs Act (the “TCJA”), will...more

Cadwalader, Wickersham & Taft LLP

Give Unto Caesar – Crypto?

On June 25, 2024, Congressman Matt Gaetz (R-FL) introduced H.R. 8822 (the “Bill”), which would add Section 6316A to the Code, allowing individuals to pay their federal income tax using Bitcoin. According to Gaetz, “enabling...more

Farrell Fritz, P.C.

Transactions with Foreign Trusts and Information Reporting on Transactions with Foreign Trusts and Large Foreign Gifts

Farrell Fritz, P.C. on

On May 8, the IRS published proposed regulations that provide guidance regarding the information reporting of transactions with foreign trusts, the receipt of large foreign gifts and loans from, and uses of property of...more

Troutman Pepper

The Enemy of the Good: Comparing Administrative v. Legislative Approaches to Cannabis Reform

Troutman Pepper on

Only one day after reports surfaced that the Drug Enforcement Administration (DEA) will proceed with rescheduling cannabis from Schedule I to Schedule III of the Controlled Substances Act (CSA), Senators Charles Schumer...more

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

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...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

Seyfarth Shaw LLP

The Week in Weed: March 2024 # 2

Seyfarth Shaw LLP on

Welcome back to The Week in Weed, your Friday look at what’s happening in the world of legalized marijuana. This week, we check in on Virginia, to see if there’s any progress on the retail market bill. We re-visit the Eastern...more

Mayer Brown

Los Angeles Faces Potential Repeal of 'Mansion Tax'

Mayer Brown on

The City of Los Angeles ULA Tax—a new city tax on certain real estate transactions, commonly referred to as the “mansion tax”—may be invalidated through the November 2024 election....more

Pullman & Comley - School Law

Connecticut Bill Targets Property Tax Exemptions for Educational Institutions

A bill has been introduced before the Connecticut General Assembly that would eliminate property tax exemptions for real property acquired by an “independent institution of higher education” on or after October 1, 2024...more

Akerman LLP

D.C. Government Publishes Proposed Rules on Tax Abatements for Residential Conversions

Akerman LLP on

Washington D.C.’s Office of the Deputy Mayor for Planning and Economic Development (DMPED) released its proposed rules establishing how the D.C. government will implement the Housing in Downtown Tax Abatement program. A...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

Polsinelli

Blockchain+ Bi-Weekly - January 2024

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The Blockchain Bi-Weekly presented by the Polsinelli Blockchain+ team is a rundown of some of the key stories in the Web3, blockchain and crypto ecosystems curated by our attorneys navigating the intersections of code, smart...more

Cadwalader, Wickersham & Taft LLP

Crypto Market Participants Push Back on Proposed Crypto Reporting Regulations

On November 13th, 2023, the IRS and Treasury held a public hearing on the proposed crypto reporting regulations.  These proposed regulations elaborate on the 2021 changes to the Internal Revenue Code that expanded the...more

Stikeman Elliott LLP

Canada’s Proposed Share Buyback Tax

Stikeman Elliott LLP on

On August 4, 2023, the Department of Finance released a revised version of its proposed 2% equity buyback tax (“Buyback Tax”) that will apply to relevant transactions that occur on or after January 1, 2024....more

Cadwalader, Wickersham & Taft LLP

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.  By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

Seyfarth Shaw LLP

The Week in Weed: October 2023 # 3

Seyfarth Shaw LLP on

Welcome back to The Week in Weed, your Friday look at what’s happening in the world of legalized marijuana. This week, we note the likely end of two Wyoming ballot initiatives. Then, we have an update on the Eastern Band of...more

Pullman & Comley - Labor, Employment and...

Retirement Plans: Will January 1, 2024 Effective Date for Age 50 Catch-Up Contribution Changes Be Delayed?

Section 401(k) Plans, Section 403(b) Plans and governmental Section 457(b) Plans generally permit employees to defer compensation on a pre-tax basis. These plans may also provide the opportunity for employees to defer...more

Cadwalader, Wickersham & Taft LLP

Congress Getting in on Barbenheimer Action, Goes for Crypto Tax Double Feature

Recent legislative action suggests that Congress is eager to resolve many unanswered crypto tax issues.  On July 11, 2023, Senators Ron Wyden and Mike Crapo released an open letter to the “members of the digital asset...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

Pullman & Comley - For What It May Be Worth

New State-Wide Property Tax Proposed in Connecticut Public Hearing Scheduled for February 27, 2023

Two bills pending before the Connecticut General Assembly seek to impose a new state-wide property tax on different classes of real property.  Currently, property taxes are only imposed at the municipal level of government. ...more

Cadwalader, Wickersham & Taft LLP

UK Government Announces DeFi Lending and Staking Consultation

In yet another development for the UK cryptocurrency sector, on 5 July 2022 the UK Government announced a consultation as to the taxation of cryptoasset loans and “staking” within the context of decentralised finance...more

Dechert LLP

The UK Investment Manager Exemption and Cryptoassets – Consultation Document

Dechert LLP on

As part of wider efforts to make Britain a global hub for cryptoassets technology and investment, on 4 April 2022 the government publicly committed to consult on extending the scope of the UK Investment Manager Exemption (the...more

Polsinelli

Capitol Hill Watch: R&D Tax Fix On the Table But Fate Uncertain

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As Congress faces a March 11 deadline to enact a Fiscal Year 2022 omnibus spending bill, advocates are making their case to federal legislators this week to include a tax title that delays or repeals the five-year...more

Proskauer - Blockchain and the Law

Congress and the IRS Make Moves to Improve Taxpayer Compliance for Cryptocurrency Transactions

IRS Commissioner Charles Rettig, testifying before Congress in April 2021, estimated the gap between taxes owed and taxes collected in the United States to be close to $1 trillion....more

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