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Internal Revenue Service Capital Gains Tax

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Morrison & Foerster LLP

Say Goodbye to Paper Cuts: Section 83(b) Elections May Now Be Filed Online

In late 2024, the Internal Revenue Service (IRS) introduced Form 15620 to provide a standardized mechanism for taxpayers to make elections under Section 83(b) of the Internal Revenue Code (the “Code”). More recently in 2025,...more

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

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On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more

Greenberg Glusker LLP

[Webinar] Maximizing Tax Benefits with Qualified Small Business Stock (QSBS): Key Insights and Strategies - March 27th, 10:00 am -...

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This presentation will cover essential aspects of QSBS eligibility, the tax benefits available under Section 1202, and practical approaches for maximizing exclusions on capital gains. This session will include recent updates,...more

McDermott Will & Emery

Lawmakers Revisit Tax Treatment of Carried Interest

McDermott Will & Emery on

The tax treatment of carried interest has long been a subject of political debate. Since 2007, almost annually, the taxation of carried interest has found its way into either proposed legislation or presidential budget...more

DLA Piper

2025 Carried Interest Tax Reform and Impact on Sponsors and Investors

DLA Piper on

On February 6, 2025, President Donald Trump met with Republican lawmakers to discuss budget priorities, proposing to end carried interest. On the same day, Democrats introduced bills in both the House and the Senate that...more

Keating Muething & Klekamp PLL

Sale of QSBS and Installment Sale Reporting

In recent years, the utilization of qualified small business stock (“QSBS”) has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax benefits from Section...more

Offit Kurman

The Top 10 Mistakes Made When Planning for Art and Other Collectibles: A Guide for Professionals and Their Clients - Mistake #1

Offit Kurman on

Navigating the tax landscape for art dealers, investors, and collectors can be a complex endeavor, but proper classification is key to maximizing tax savings and avoiding pitfalls....more

Goodwin

A New Form Section 83(b) Election: IRS Form 15620

Goodwin on

As part of US tax planning for founders, employees, board members, and other individual service providers who receive equity that is subject to vesting in connection with their services, Section 83(b) elections are frequently...more

Allen Barron, Inc.

The Statute of Limitations for an IRS Audit

Allen Barron, Inc. on

What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit? How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of...more

DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

DLA Piper on

The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

Kohrman Jackson & Krantz LLP

Navigating Section 1014 and the TCJA: A Deep Dive into the IRS Ruling on Basis Adjustments

Understanding the nuances of the Internal Revenue Code (I.R.C.) is crucial for effective estate planning and tax strategy. For example, estate planners must be familiar with the tax basis adjustment provisions in 26 U.S.C. §...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Allen Barron, Inc.

You Need to Review Your Irrevocable Trust

Allen Barron, Inc. on

Do you employ an irrevocable trust or trusts as part of your estate plan? You need to review your irrevocable trust to ensure it still delivers the benefits intended. It is generally possible to modify an irrevocable trust,...more

Venable LLP

Earnouts and Their Tax Treatment

Venable LLP on

As buyers and sellers engage in negotiations for the sale of a business, often there may be disagreements as to the value and expected growth of that business. One party might currently value the business higher than the...more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Davidoff Hutcher & Citron LLP

If It's Too Good To Be True...The Latest Guidelines from the IRS

There are a lot of very smart tax attorneys out there who are trying to figure out something new, and yet there’s very little innovation.  Almost all techniques that we use are incremental variations of an older technique...more

DarrowEverett LLP

1031 Exchanges and the Complexities of Seller Financing

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With interest rates nearly the highest they’ve been in decades, but property prices still high, sellers and buyers are looking for ways to finance real estate transactions while also availing themselves of IRC § 1031’s...more

Allen Barron, Inc.

Estate and Tax Planning for US Expatriates

Allen Barron, Inc. on

What are the most important elements of estate and tax planning for US expatriates?  Are you planning to move out of the United States?  Are you a US taxpayer who lives and works outside of the country?  What are some of the...more

Allen Barron, Inc.

Tax Tips for Lottery Winners

Allen Barron, Inc. on

Today is the anniversary of the largest Powerball lottery victory in the United States of $2.04 billion.  Just over the $1.765 billion jackpot claimed last month (Oct 2023).  What are some tax tips for lottery winners and...more

Blank Rome LLP

NFTs: A Tale of Two Classifications

Blank Rome LLP on

On March 21, 2023, the Department of the Treasury and the Internal Revenue Service (“IRS)” released Notice 2023-27, announcing their intent to provide guidance on classifying certain non-fungible tokens (“NFTs”) as...more

Bowditch & Dewey

Cryptocurrency Wash-Sale Loss Harvesting

Bowditch & Dewey on

The IRS wash-sale rule does not currently apply to cryptocurrency because the IRS considers virtual currencies to be property rather than securities. In general, a taxpayer who exchanges cryptocurrency for goods, services or...more

Seward & Kissel LLP

NFT Means Never Forget Taxes: Redux

Seward & Kissel LLP on

The Internal Revenue Service released Notice 2023-27 (the “Notice”), providing guidance on the federal tax treatment of nonfungible tokens (“NFTs”). In a prior SKRYPTO blogpost, we noted that investors selling NFTs could be...more

Foodman CPAs & Advisors

La Disminución Del Valor Cripto No Es Igual A La Deducción Fiscal Cripto

Dado que estamos en pleno apogeo de la temporada de impuestos, muchos contribuyentes están explorando la posibilidad de reclamar una deducción de impuestos cripto sobre sus activos cripto “devaluados”. Los contribuyentes...more

ASKramer Law

Can You Write Off Crypto Losses? IRS Says Intention Matters

ASKramer Law on

A taxpayer’s investment losses, including losses on digital assets such as cryptocurrencies and non-fungible tokens (NFTs), are not deductible unless the taxpayer’s activities rise to the level of “investment activities” or...more

ASKramer Law

IRS Takes a New Approach to NFT Taxes and ‘Collectibles’

ASKramer Law on

Until very recently, the IRS has been silent about the tax treatment of non-fungible tokens (NFTs). An almost unknown market in 2020, NFTs skyrocketed to prominence in 2021 with a capitalization at the beginning of 2021 of...more

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