News & Analysis as of September 7, 2025

Capital Losses

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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 -

Proposed Rule Modifies Timing of "Hot Asset" Reporting

Holland & Knight LLP on 8/22/2025

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

Business Taxation of Hedging Transactions Part V: Consolidated Groups

ASKramer Law on 5/3/2024

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

Business Taxation of Hedging Transactions Part IV: Tax Timing

ASKramer Law on 4/26/2024

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

Tax Court in Brief | Powell v. Comm’r | IRS Forms vs. Statutes – Net Capital Loss Deduction

Freeman Law on 10/19/2022

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

The Tax Court in Brief - August 2021 #3

Freeman Law on 8/27/2021

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 9 – August 13, 2021 - Manuelito B. Rodriguez &...more

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