Tax Planning, Asset Management, Internal Revenue Code (IRC)

Business Taxation of Hedging Transactions Part II: Common Situations

ASKramer Law on 4/12/2024

What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

Federal Income Taxation of Intellectual Property Development and Cost Recovery

Gray Reed on 4/10/2024

Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful...more

Top Tax and Legal Considerations for Wealthy Families Going Global

Greenberg Glusker LLP on 10/5/2023

In recent years, we have seen high net-worth and ultra-high-net-worth families become, increasingly, “global citizens.” As families and their assets touch multiple jurisdictions, a myriad of issues become especially important...more

Massachusetts Doubles Estate Tax Threshold as Part of $1 Billion Tax Reform Act

Goulston & Storrs PC on 10/5/2023

On October 4, 2023, Massachusetts enacted a new law called “An Act to improve the Commonwealth’s competitiveness, affordability, and equity” (the “Act”). The Act makes several tax law changes relevant to Massachusetts...more

Taxation of Derivatives Held by Investors: What to Know

ASKramer Law on 3/22/2023

The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...more

What is a Trust?

Freeman Law on 2/9/2022

Trusts - Trusts play an important role in estate and tax planning. A trust is a fiduciary arrangement that allows a trustee to hold legal title to assets for the benefit of a beneficiary. The beneficiary is, in turn, said...more