News & Analysis as of September 2, 2025

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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 -

Tax-Loss Harvesting Part II: The Wash Sales Rule

ASKramer Law on 7/25/2025

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

Senate Tax Bill: Key Points for the Investment Funds Industry

DLA Piper on 6/24/2025

The US Senate released a draft tax bill (Senate Tax Bill) on June 16, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management community, with a focus on how the Senate Tax Bill...more

Senator Tillis Introduced a Bill Taxing Proceeds of Litigation Financing Agreements

Proskauer - Tax Talks on 6/3/2025

Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more

YA Global Brings its Fight to the Appellate Level

Cadwalader, Wickersham & Taft LLP on 5/29/2025

On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more

The One Big Beautiful Bill’s impact on investments in BDCs

Eversheds Sutherland (US) LLP on 5/28/2025

On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...more

Key Updates to the House Committee on Ways and Means’ Proposed Tax Bill

DLA Piper on 5/15/2025

On May 12, 2025, the House Committee on Ways and Means Chairman Jason Smith (R-MO) released an amended 389-page bill, entitled “The One, Big, Beautiful Bill,” and the staff of the Joint Committee on Taxation released a...more

Cannabis ESOPs Provide Solutions for Operators

Blank Rome LLP on 5/2/2025

As we enter Q2 of 2025, the cannabis industry has become increasingly pessimistic about the elimination of Section 280E of the Internal Revenue Code, whether via rescheduling or otherwise. Rescheduling appears unlikely in the...more

[Webinar] Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning - June...

Strafford on 5/30/2024

This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more

Not So Cryptic: IRS Increases Oversight on Cryptocurrency Income Tax Reporting Requirements

Holland & Knight LLP on 5/2/2024

Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued last year, the IRS recently increased its oversight of cryptocurrency...more

Tokenization Lawyer – 5 Reasons Why You Might Need One

Oberheiden P.C. on 5/17/2022

What is Tokenization? Tokenization is the process of converting an asset into a token on the blockchain. It operates by dividing—or fractionalizing—the ownership of an asset (whether the asset is a piece of real estate or...more

The Benefits of Investing in a QOF

McDermott Will & Schulte on 10/21/2021

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

Bowditch & Dewey on 9/29/2021

In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more

Key Takeaways | Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW

McDermott Will & Schulte on 7/28/2021

During a recent program discussing the latest government enforcement efforts related to cryptocurrency, we spoke with Gary Alford, one of the leading Internal Revenue Service (IRS) agents in their crypto enforcement efforts,...more

[Webinar] Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW - June 28th, 12:00...

McDermott Will & Schulte on 6/15/2021

Following the US Internal Revenue Service’s (IRS) announcement of “Operation Hidden Treasure,” companies and individuals should prepare for increased scrutiny of virtual currency transactions. Unveiled in March, the operation...more

GameStop, Taxes, and the Next Trade

Bowditch & Dewey on 2/15/2021

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

What You Should Know About Day Trading

Bowditch & Dewey on 8/24/2020

Since the start of the global pandemic this past March, day trading has become a way for some to spend their newfound free time while quarantining at home. For others, day trading has filled the void that was left when sports...more

When Limited Liability Yields To Transferee (Personal) Liability

Farrell Fritz, P.C. on 1/20/2020

“Limited Liability” The experienced or well-informed investor recognizes that there is an element of risk in every business venture. They understand that the cash or other property they have contributed to the venture may be...more

Weekly IRS Roundup December 30, 2019 – January 3, 2020

McDermott Will & Schulte on 1/7/2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 30, 2019 – January 3, 2020. December 30, 2019: The IRS issued a news release announcing...more

Upper Tribunal Overturns Decision on Tax Treatment of Management Fee Rebates

Akin Gump Strauss Hauer & Feld LLP on 8/30/2019

The Upper Tribunal (UT) has found that amounts paid by Hargreaves Lansdown (HL) (an investment platform service provider) to its customers, which represented rebates received from investment fund managers, were “annual...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on 7/23/2018

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

The Year of Bitcoin: Gains Subject to Tax by the IRS

Bowditch & Dewey on 12/14/2017

The year 2017 could be described as the year of the Bitcoin and other “virtual currencies,” with Bitcoin having appreciated 1800% since the beginning of the year and Ethereum, at one point, having appreciated 8,000% since the...more

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

Akin Gump Strauss Hauer & Feld LLP on 11/22/2017

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

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