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Income Taxes › Securities

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
ASKramer Law

Tax-Loss Harvesting Part III: Investment Strategies

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Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment  returns, while offsetting...more

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

ASKramer Law on

At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more

Mayer Brown

Régime fiscal de faveur des BSPCE : non éligibilité en l’absence de rémunération du bénéficiaire

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La Cour administrative d’appel de Nancy précise la définition d’activité permettant de bénéficier du régime de faveur des BSPCE (CAA Nancy, 15 mai 2025, n° 22NC03173)....more

McDermott Will & Schulte

Economic Ownership of Shares Transferred as Collateral

McDermott Will & Schulte on

Dividends from shares are taxable for shareholders, even if the dividends do not remain with them economically. This (not entirely new) finding can be gleaned from a recent Federal Fiscal Court (BFH) ruling in which the...more

Cadwalader, Wickersham & Taft LLP

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

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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

Principales mesures issues de la Loi de finances pour 2025

Mayer Brown on

Du fait de l'entrée en vigueur de la Loi de finances pour 2025, l'équipe fiscale de Mayer Brown revient sur les principales dispositions applicables en matière de fiscalité de l'entreprise (1) et de fiscalité patrimoniale...more

Sheppard Mullin Richter & Hampton LLP

Reminder about Annual ISO/ESPP Reporting in January 2025 and New Section 83(b) Election Form

Sheppard Mullin Richter & Hampton LLP on

Annual Reporting on ISO/ESPP Transactions - As originally discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require...more

Mayer Brown

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

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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

Foley & Lardner LLP

Unlocking the Power of Equity-Based Incentive Compensation: Basics of Profits Interests

Foley & Lardner LLP on

This article is the fifth in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees?...more

Foley & Lardner LLP

Unlocking the Power of Equity-Based Incentive Compensation: An Overview of Incentive Stock Options (ISOs)

Foley & Lardner LLP on

This article is the third in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees?...more

K&L Gates LLP

Doing Business in Australia

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Australia welcomes new business and foreign investment by providing a strong economy, a stable political environment and a skilled and talented workforce. Our comprehensive guide to Doing Business in Australia has been...more

McNees Wallace & Nurick LLC

Bond Issue Fundamentals: A Guide to the Participants and the Process - Updated

McNees Wallace & Nurick LLC on

A bond issue (a debt obligation of a local government) is often perceived as a mystery for many Pennsylvania local government officials and solicitors. The securities and tax regulations governing municipal bonds have grown...more

Foodman CPAs & Advisors

Alivio Del IRS Para Ciertos Documentos Internacionales Presentados Tarde

Foodman CPAs & Advisors on

El 11/08/23, el IRS anunció que, en las circunstancias adecuadas, los contribuyentes internacionales podrán utilizar una nueva herramienta totalmente electrónica para presentar solicitudes de alivio de multas del IRS para...more

Foodman CPAs & Advisors

IRS Relief For Certain Late-Filed International Documents

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On 8/11/23, the IRS announced that under the right circumstances, international taxpayers will be able to use a new, fully electronic tool to submit penalty IRS relief requests for a few late-filed forms: a fax...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 & Schulte

Weekly IRS Roundup March 13 – March 17, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...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

Pillsbury Winthrop Shaw Pittman LLP

Legal Implications of Secondary SAFT Sales

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Simple Agreements for Future Tokens pose difficult and controversial legal questions under U.S. securities, commodities and tax laws. SAFT holders face significant difficulties in securing liquidity, and regulatory issues...more

Opportune LLP

Creditor Income Tax Considerations in the Form of Ownership for Upstream Oil & Gas Investors

Opportune LLP on

Find out why upstream oil and gas investors should take into account income tax considerations during and after a restructuring event.  ...more

Perkins Coie

Blockchain and the Law - Overview of token sales and bitcoin property rights

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On March 29, 2017, Perkins Coie partner Dax Hansen and associate Josh Boehm were invited to the Cyber Initiative at Stanford Law School to deliver a presentation on several cutting-edge legal issues relating to blockchain...more

Farrell Fritz, P.C.

Potential Relief for Employee Option Exercises

Farrell Fritz, P.C. on

Employees must generally recognize income for tax purposes upon the receipt of employer stock to the extent that the fair market value of the stock received is greater than the amount, if any, paid by the employee for the...more

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

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On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Orrick, Herrington & Sutcliffe LLP

New Countries Eligible for Italy's White List

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In the Official Gazette No. 195 of 22 August 2016, the Italian Government published the Ministerial Decree of 9 August 2016 (the "Decree") that amended the list of countries and territories "allowing an adequate exchange of...more

Goodwin

Waivers of Ownership Limitation Provisions in REIT Charters

Goodwin on

I. Why Do REITs Have Ownership Limits in the First Place? - Ownership limitation provisions are designed primarily to protect one of a REIT’s most valuable assets – its status as a REIT under the federal income tax...more

Katten Muchin Rosenman LLP

Former Chief Operating Officer Settles SEC Fraud Claims

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The Securities and Exchange Commission recently announced that Peter Jenson, the former chief operating officer of Harbinger Capital Partners LLC, agreed to pay a $200,000 civil penalty to resolve charges that he aided the...more

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