The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more
7/8/2025
/ Corporate Taxes ,
Employee Benefits ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
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Trump Administration
The Internal Revenue Service (IRS) and the Department of the Treasury issued a 282 page notice of proposed rulemaking regarding digital assets and broker reporting on Aug. 26 (the Proposed Regulations), nearly two years after...more
9/14/2023
/ Brokers ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Infrastructure Investment and Jobs Act (IIJA) ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
NPRM ,
Payment Processors ,
Popular ,
Public Hearing ,
Reporting Requirements ,
Stablecoins ,
U.S. Treasury
Hedge fund managers should be aware of two recent U.S. Tax Court memorandum decisions that shed further light on when a taxpayer, such as a hedge fund, is considered to be a "trader" or "investor" for tax purposes -- a...more