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Capital Gains Securities

ASKramer Law

Tax-Loss Harvesting Part I: Overview

ASKramer Law on

What is tax-loss harvesting? “Tax-loss harvesting,” in its simplest form, is the sale of a capital asset at a loss to “mop up” tax that would otherwise be due on capital gain from the sale of another capital asset. Capital...more

Cadwalader, Wickersham & Taft LLP

Tax Court Calls Bluff on Hedge Fund’s Basket Option Contracts

The Tax Court recently held that a hedge fund’s basket option contracts were in substance tax ownership of the underlying basket securities. The hedge fund, through its affiliated entities, entered into 10 basket option...more

Mayer Brown

La prise en compte des reprises et dotations des provisions pour dépréciation de titres de participation pour le calcul de la...

Mayer Brown on

Dans une décision mentionnée aux tables du Recueil Lebon, le Conseil d'Etat affirme la légalité de la doctrine administrative du 3 avril 2024, selon laquelle doivent être prises en compte, pour le calcul de la plus-value...more

Mayer Brown

Going in Circles: The IRS Limits Puerto Rico Source Rules in Responding to Aggressive Tax Positions

Mayer Brown on

The tax advantages for US individuals who become bona fide residents of US possessions can be substantial. These tax advantages have lured more than a few taxpayers to take unreasonably aggressive positions that they are...more

ASKramer Law

Taxation of Foreign Currency Transactions Part V: Hedged Executory Contracts

ASKramer Law on

What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more

Proskauer Rose LLP

UK Tax Round Up - March 2023 - 2

Proskauer Rose LLP on

Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

McDermott Will & Emery

What a Capital Gains Rate Hike Could Mean

McDermott Will & Emery on

Although it is unclear what will happen to capital gains rates over the course of the next year, it is important to discuss the implications of what a rate hike could mean. While we don’t know for certain whether the capital...more

Farrell Fritz, P.C.

Responding To The Democratic Party’s Tax Plans

Farrell Fritz, P.C. on

The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

Smith Debnam Narron Drake Saintsing & Myers,...

When Financial Planning Meets Family Law

Late 2016, the Minnesota Supreme Court decided the case of Curtis v. Curtis (887 N.W.2d 249) and in so doing provided a lesson in how to invest $2,000,000.00 to maximize your return in an alimony case....more

Adler Pollock & Sheehan P.C.

Estate Planning Pitfall - You’re selling your interest in a charitable remainder trust

Recently finalized regulations eliminate a potential tax shelter involving the sale of an interest in a charitable remainder trust. This brief article offers an example of how the tax shelter worked before the new regs and,...more

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