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Proskauer Rose LLP

Wealth Management Update - February 2025

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February 2025 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February applicable federal rate (“AFR”) for use with a sale to a defective grantor...more

Proskauer - Tax Talks

Tax Proposals Potentially Being Considered by the U.S. House Budget Committee in Reconciliation

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On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman Brendan Boyle, D-PA

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy debates in Congress. In this episode of “The Cloakroom with Peter Roskam,”...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

ASKramer Law

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

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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

ASKramer Law

Taxation of Foreign Currency Transactions Part I: Definitions and Rules for Taxing Foreign Currencies

ASKramer Law on

Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more

DarrowEverett LLP

Accidental Termination on Purpose? S Corp Ruling Could Be Huge For QSBS Owners

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Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...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 II – Code...

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This second installment of my multi-part series on Subchapter S is focused on two Code Sections, namely IRC Section 1375 and IRC Section 1362(d)(3)....more

Allen Barron, Inc.

The High IRS Tax Rates on a Foreign Trust

Allen Barron, Inc. on

Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more

Burr & Forman

Changes in Tax Rates for 2023

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The IRS has issued Revenue Procedure 2022-38, which sets forth inflation-adjusted items for various provisions of the Internal Revenue Code which will be applicable in 2023. Here are some of the highlights...more

Foster Garvey PC

The Build Back Better Act Was Passed in the House and Is Now in the Senate

Foster Garvey PC on

On November 19, 2021, HR 5376, the 2,476-page bill, commonly known as the Build Back Better Act, was passed by the U.S. House of Representatives by a vote of 220-213. The House’s vote on HR 5376 was held after the...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Freeman Law

Congress Readies New Round of Tax Increases

Freeman Law on

The House Committee of Ways and Means (the “House”) has been busy the last few days. Indeed, the House continues to mark up and work through potential revenue raisers (i.e., tax increases) to help pay for recent legislative...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposal on Domestic Businesses

Bowditch & Dewey on

On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more

Polsinelli

Additional Guidance Issued for President Biden’s American Jobs and American Families Plan

Polsinelli on

In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. Among the proposed changes included in the “American Families Plan” was the increase of the tax rate that...more

Williams Mullen

The American Families Plan: Tax Implications for Real Estate Owners and Developers

Williams Mullen on

On April 28, 2021, President Biden announced a plan to expand benefits for lower- and middle-income Americans under his “American Families Plan” (the “Plan”). To pay for the Plan’s benefits, President Biden has proposed...more

Foster Garvey PC

Tax Planning Out of Fear Usually Doesn’t End Well

Foster Garvey PC on

It is not unreasonable to anticipate that there will be a federal tax policy transformation following a change in the political control of the White House, the U.S. Senate and the U.S. House of Representatives. What may be...more

Freeman Law

So You Made Money on GameStop, Now What? A Primer on Capital Gains

Freeman Law on

The GameStop stock saga will undoubtedly go down in history as one of the most mystifying market events Wall Street has ever seen. Indeed, the markets have seen a massive influx of new retail investors into the space. But...more

Mayer Brown

Final Like-Kind Exchange Regulations Contain Much-Needed Clarity for Natural Resource-Related Assets

Mayer Brown on

In December of 2020, the US Internal Revenue Service (the “IRS”) issued final regulations (T.D. 9935) (the “Final Regulations”) on like-kind exchanges under Section 1031 of the Internal Revenue Code of 1986, as amended. The...more

Bowditch & Dewey

Can I Withdraw Funds From My Retirement Account During COVID-19?

Bowditch & Dewey on

The Paycheck Protection Program money is spent, the temporary $600 weekly unemployment supplement is over, and we still need money. We could draw on our savings, sell investments, or take out a loan against our home. Usually,...more

Coblentz Patch Duffy & Bass

2020 Tax Planning: Benefits of GRATs

Now may be an opportune time to gift assets out of your estate, particularly through an estate planning technique known as the Grantor Retained Annuity Trust (“GRAT“)—a small silver lining of the alarming pandemic and down...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

Troutman Pepper Locke

The SECURE Act Brings Significant Changes for Retirement Plans and IRAs

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The Setting Every Community Up for Retirement Enhancement Act of 2019 (the SECURE Act), signed into law on Dec. 20, 2019, will have a wide-ranging impact on tax-qualified retirement plans and individual retirement accounts,...more

Kramer Levin Naftalis & Frankel LLP

New Treasury Regulations and IRS Notice Regarding Withholding on Dividend Equivalent Payments to Foreign Holders

On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

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