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Internal Revenue Service Capital Gains Stocks

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.  
ASKramer Law

Tax-Loss Harvesting Part III: Investment Strategies

ASKramer Law on

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

DarrowEverett LLP

Unlocking Tax-Free Gains: The Power of QSBS in Mergers & Acquisitions

DarrowEverett LLP on

Internal Revenue Code (IRC) Section 1202 offers a significant tax incentive for investors in qualified small business stock (QSBS). This provision allows eligible shareholders to exclude up to 100% of capital gains realized...more

Cadwalader, Wickersham & Taft LLP

IRS Takes Partnership Entity-Level View on FIRPTA’s Publicly Traded Stock Exception

The IRS has finally taken a view on the exception to FIRPTA (the Foreign Investment in Real Property Tax Act) for publicly traded stock of a United States real property holding corporation (a “USRPHC”) that is held by a...more

Rivkin Radler LLP

S Corps with Real Property: Separating Shareholders & Partnership Envy

Rivkin Radler LLP on

Tax Alchemy? How many of you remember Section 138509 of the Ways and Means Committee’s markup last September of what would have been the Build Back Better Act? (A moment of silence, please.) Allow me to jog your memory....more

Foley & Lardner LLP

Qualified Small Business Stock: Some Interesting Questions

Foley & Lardner LLP on

Section 1202 is a once-obscure tax saving provision that has come into prominence in the last few years. Originally passed in 1993 as a 50% capital gain exclusion, it has been amended several times since. In its current...more

Farrell Fritz, P.C.

Carried Interest, Qualified Small Business Stock, And Excluded Gain: So Happy Together?

Farrell Fritz, P.C. on

Water, Water Everywhere, Nor Any Drop to Drink- At the beginning of every week, after posting that week’s article, I start to think about a topic for the next post. There are times when I struggle to find something that...more

McDermott Will & Schulte

Weekly IRS Roundup October 28 – November 1, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28 – November 1, 2019. October 30, 2019: The IRS issued an Action on Decision in which...more

Farrell Fritz, P.C.

Stock Sales And Employee-Minority Shareholders: What Does It Take To Make A Deal?

Farrell Fritz, P.C. on

If you’ve been representing closely held businesses long enough, then the “conversation transcribed” below should sound familiar to you. I have had several versions of this exchange in the last few months. The common...more

Proskauer - Blockchain and the Law

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more

Polsinelli

Small Business Investors Can Save Big with New IRS Code Amendments

Polsinelli on

Recent amendments to the Internal Revenue Code of 1986 (the Code) have significantly expanded the opportunity for tax savings under Section 1202. Section 1202, which was originally added to the Code in 1993, provides relief...more

Troutman Pepper

Planning For Qualified Dividend Income When Taking Foreign Companies Public - Tax Update Volume 2015, Issue 2

Troutman Pepper on

Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more

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