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The Biden Administration Re-Proposes to Tax Carried Interests as Ordinary Income

On March 28, 2022, the Biden Administration proposed to tax “profits” or “carried” interests as ordinary income and impose self-employment tax on income and gains from these interests for certain partners in investment...more

The Biden Administration Proposes Changes to the Taxation of Real Property

On March 28, 2022, the Biden Administration proposed changes to the taxation of real property. Restrict Deferral of Gain for Like-Kind Exchanges under Section 1031 - The Biden Administration has proposed to limit the...more

The Biden Administration Proposes Changes to the Taxation of Cryptocurrency Transactions

On March 28, 2022, the Biden Administration proposed certain very limited changes to the taxation of cryptocurrency transactions. The proposals do not change the current treatment of cryptocurrency as property for federal...more

The Biden Administration Proposes Changes to the U.S. International Tax Rules

Introduction and Summary - On March 28, 2022, the Biden Administration proposed changes to the U.S. international tax rules. In short, the Biden Administration proposed to: Enact a 15% minimum “undertaxed profits...more

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

IRS Releases Guidance on Requirements for Limited Liability Companies to Qualify as Tax-Exempt Entities

On October 21, 2021, the Internal Revenue Service (the “IRS”) released Notice 2021-56 (the “Notice”), which sets forth the additional requirements a limited liability company (“LLC”) must satisfy to obtain a determination...more

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