From Legislation to Implementation: Understanding Section 1202 Changes — Troutman Pepper Locke Podcast
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!
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Episode 26: Talking Tax Reform and Executive Comp
Executive Compensation Packages – Interview with David Lagasse, Member, Mintz Levin
What Individuals and Businesses Need to Know About the American Taxpayer Relief Act
Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more
On January 6, 2025, Prime Minister Justin Trudeau announced his resignation as prime minister and the prorogation of Parliament until March 24, 2025. At the federal level, prorogation is an act by the Governor General,...more
As explained in a prior blog post, an employee who timely files a Section 83(b) election will be taxed on the fair market value of property transferred (typically restricted stock) to him or her in exchange for services on...more
Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more
What are the tax accounting rules for hedges? Whether or not a qualified tax hedge is properly identified, it must be tax accounted for under a method that clearly reflects income. The timing of gains and losses on hedges...more
After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...more
Nearly two years after being enacted by the state legislature, and one year after being struck down by a lower court, the Washington state capital gains tax has been reinstated as constitutional, and the first returns and...more
Summary: In this 49-page opinion the Tax Court addresses a deficiency arising from the charitable contribution of appreciated shares of stock in a closely held corporation to a charitable organization that administers...more
It is a rainy day in the Pacific Northwest with chances of snow showers. For those taxpayers that reside in the state of Washington or own highly appreciated capital assets located in the state, their day just got a bit...more
The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more
On April 12, 2022, the Internal Revenue Service announced that starting this month, it will send letters to taxpayers requesting that they take corrective actions related to the reporting of investments in qualified...more
Effectively Connected Income - Unlike FDAP income, the United States taxes effectively connected income (“ECI”) on a net basis. Effectively connected income is income that is effectively connected with the conduct of a U.S....more
U.S. taxpayers have an obligation to both report their cryptocurrency transactions to the IRS and pay taxes on it. Individuals who hold on to their cryptocurrencies as an investment are subject to short- and long-term capital...more
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
Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more
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
It appears the wild ride for traders in GameStop (GME) stock has ended with shares trading at a fraction of what they were trading just a few weeks ago. Shares which once soared from around $20 a shares to a high of $380, as...more
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
Individuals, estates, and trusts that paid significant amounts of the 3.8% net investment income tax or the 0.9% additional Medicare tax in 2016 or later years should consider filing protective claims for refund of those...more
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
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
We all read the headlines. Virtual currencies are a hot button topic. Even Facebook is developing their own virtual currency. It is easy to understand the attraction. The use of a virtual currency is anonymous. Account...more
We Want You- One of the most challenging problems facing a business is how to attract, and then retain, qualified employees. The competition among businesses can be fierce and, in order to succeed, businesses have, over...more
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
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