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Tax Liability Tax Reform 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

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

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

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

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

Polsinelli

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

Polsinelli on

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

Lewis Roca

2021 Arizona Tax Updates

Lewis Roca on

TRANSACTION PRIVILEGE TAX UPDATES LEGISLATION - Senate Bill 1110, Chapter 443. Tribal Exemptions. This bill codified the following exemptions applicable to Indian tribes and tribal members at A.R.S. § 42-5121 et seq.: (1)...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

Stinson LLP

NIIT Expansion Under Proposed Build Back Better Act Includes Subtle Tax Increase on Sales of Private Businesses

Stinson LLP on

In general, tax experts were pleased that the Build Back Better Act, passed recently by the U.S. House of Representatives, did not include many of the tax increases previously proposed by the Biden Administration. ...more

Mitchell, Williams, Selig, Gates & Woodyard,...

IRS Says Not So Fast to States' Attempts to Convert High State and Local Tax Obligations to Charitable Deductions to Escape TCJA...

In Notice 2018-54, the IRS has notified taxpayers that proposed regulations are forthcoming which will deny state attempts to convert a taxpayer’s state and local tax obligations to a charitable deduction in order to avoid...more

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