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Seward & Kissel LLP

Private Equity Investment into NFL Teams: Tax and Business Considerations

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Owning an NFL team is no longer a fantasy. The National Football League (the “NFL” or the “League”) voted to allow minority stakes to be sold to private equity firms (“PE”). However, according to NFL.com, “an executive from...more

Foster Swift Collins & Smith

Legal-Ease: Steps for When a Loved One Passes Away - Part Two

This is the second of three articles addressing the topic of what needs to be done when a spouse or loved one passes away. My last article addressed the immediate things that need to be done prior to the decedent’s funeral...more

Ward and Smith, P.A.

Tax Treatment of the Sale of Social Club Assets Upon Liquidation

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Since 1916, Congress has exempted from income taxation clubs formed to facilitate social interaction between its members.  As a result, country clubs, hunting and fishing clubs, college sororities and fraternities, and...more

Rivkin Radler LLP

Intercompany Loan Treated As Constructive Distribution and Contribution

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Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...more

Blake, Cassels & Graydon LLP

What You Need to Know About the Pension Investment Landscape in 2024

The new year brings new considerations for pension fund and sovereign investors. Below are a few key topics to keep in mind going into 2024...more

Patterson Belknap Webb & Tyler LLP

Protective Refund Claims in Light of Pending Moore v. United States Decision

Taxpayers, including some of the firm’s current and former clients, may be affected by the outcome of the Supreme Court case Moore v. United States, which will address the constitutionality of the Section 965 “Transition...more

ArentFox Schiff

Investigations Newsletter: Arkansas Men Convicted in $18 Million Global Investment Fraud Conspiracy

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Arkansas Men Convicted in $18 Million Global Investment Fraud Conspiracy - A federal jury in the Western District of Arkansas convicted four men of conspiracy to commit wire fraud, wire fraud, and conspiracy to commit money...more

Rivkin Radler LLP

Debt or Equity? The Never-Ending Question For Closely Held Businesses

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What Was Intended? Transactions between commonly controlled, closely held businesses are often conducted in an informal manner. This is unfortunate because, in the absence of documentation, it is sometimes difficult to...more

McDermott Will & Emery

Weekly IRS Roundup April 17 – April 21, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2023 – April 21, 2023...more

McDermott Will & Emery

IRS Releases Memorandum on Deducting Cryptocurrency Losses

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On January 13, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice Memorandum (CCA 202302011) concluding that taxpayers cannot claim a deduction for cryptocurrency losses that have, absent a sale or other...more

Guidepost Solutions LLC

Why Family Offices Turn to Embedded Security Managers for Security, Safety, and Peace of Mind.

Guidepost Solutions LLC on

A recent Forbes article details the significant growth of family offices worldwide, particularly in North America. While not as large as titans like Walton Enterprises LLC or Bezos Expeditions, these new single and...more

Gerald Nowotny - Law Office of Gerald R....

How Can I Tell You?

I am on the record stating that as far as musical taste is concerned, I am a "horn band" aficionado - Tower of Power, Chicago, Blood, Sweat and Tears. By default, I am not an aficionado of folk music and ballads. Having said...more

McDermott Will & Emery

Weekly IRS Roundup September 12 – September 16, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 12, 2022 – September 16, 2022...more

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

Foodman CPAs & Advisors

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

Gray Reed

Taxpayer Guidelines for Cryptocurrency in 2021

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Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more

Kramer Levin Naftalis & Frankel LLP

Virtual Currency

On Oct. 9, 2019, the Internal Revenue Service (the “Service”) issued Revenue Ruling 2019-24 concerning the tax consequences of virtual currency hard forks, as well as FAQs on the taxation of virtual currency generally. This...more

Foodman CPAs & Advisors

Taxpayers, have you sold, received, exchanged or acquired Virtual Currency?

Foodman CPAs & Advisors on

During the month of October 2019, IRS issued Revenue Ruling 2019-24,  FAQ’s on Virtual Currency Transactions and a DRAFT Form of Schedule 1,  which, for the first time presents the question:  “At any time during 2019, did you...more

Polsinelli

IRS Issues Sends Letters to Over 10,000 Taxpayers with Cryptocurrency Transactions Without Providing Anticipated Guidance

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On July 26, 2019, the IRS announced that it was in the process of sending letters to over 10,000 taxpayers with a history of cryptocurrency transactions by the end of August, noting that the letters were sent to taxpayers...more

McDermott Will & Emery

Watch Your Mailbox: IRS Letters Warning of Cryptocurrency Non-Compliance on Their Way

McDermott Will & Emery on

On July 26, 2019, the Internal Revenue Service (IRS) issued a press release informing the public that it is sending more than 10,000 letters to taxpayers with potentially unreported (or misreported) virtual currency...more

Foodman CPAs & Advisors

2018 is almost over and still no guidance from IRS on the treatment of Virtual Currency

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On September 19, 2018, the House Ways and Means Committee wrote a letter to the IRS urging the IRS to “issue updated guidance, providing additional clarity for Taxpayers seeking to better understand and comply with their tax...more

Foodman CPAs & Advisors

Lo que sabemos sobre el Cumplimiento Crypto y los impuestos federales de los EE. UU.

La última Notificación emitida por el IRS sobre Criptomoneda fue el Aviso 2014-21 publicado el 25 de Marzo del 2014 que brinda orientación en forma de respuestas a preguntas frecuentes (“Frequently Asked Questions”). ...more

Foodman CPAs & Advisors

What we know about Crypto Compliance and US Federal Taxes

The last Notice issued by the IRS on Cryptocurrency was Notice 2014-21 posted on March 25, 2014 providing guidance in the form of answers to frequently asked questions. ...more

Foodman CPAs & Advisors

Bitcoins y el IRS: Reportaje y Almacenamiento

La posesión de moneda virtual, también conocida como criptomoneda, es legal tanto en los EE.UU como en muchas otras partes del mundo. La forma más conocida de moneda virtual es Bitcoin. ...more

Foodman CPAs & Advisors

The “J5” is on to Cryptocurrencies

The Organisation for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. The result of this “call to action” was the establishment of an...more

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