Popular, Tax Planning, Income Taxes

New Option for Excess Fee Income Rebates in Private Equity Funds for Non-US and US Tax-Exempt Investors

Mintz - Tax Viewpoints on 7/14/2025

This update discusses a new and interesting development with respect to how certain non-US and US tax-exempt investors can receive a “rebate” of previously paid management fees with respect to their investments in private...more

Trump Accounts: The New Child Savings Account Established Under the One Big Beautiful Bill Act

Foley & Lardner LLP on 7/10/2025

On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBA). The OBBA established a new type of tax-advantaged savings account for minors, known as “Trump Accounts.” While the specific details of...more

2025 Perspectives in Private Equity: Tax Analysis

Akin Gump Strauss Hauer & Feld LLP on 4/18/2025

Major portions of the U.S. tax code are scheduled to expire at the end of 2025, and as the U.S. tax landscape faces potential upheaval, private equity firms must stay vigilant and adaptable. Proactively engaging with tax...more

IRS Changes Course on Income Tax Impact of Employee Retention Credit

Ballard Spahr LLP on 4/9/2025

On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Plan in Advance: Deferred Revenue Tax Considerations in M&A Transactions

Alston & Bird on 10/23/2024

Our Federal Tax Group discusses the tax treatment of deferred revenue or advance payments in M&A transactions. The tax treatment of deferred revenue differs from the treatment for financial accounting purposes....more

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

Mayer Brown on 7/18/2024

In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...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

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on 8/24/2023

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more

IRS Says Crypto Protocol Changes Are Not Taxable

Cadwalader, Wickersham & Taft LLP on 5/25/2023

On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more

Back to the Future ... Cryptocurrency Tax Reporting

Cadwalader, Wickersham & Taft LLP on 1/26/2023

The cryptocurrency industry may be breathing a sigh of relief following the release of recent IRS guidance on cryptocurrency tax reporting, which effectively postpones the January 1, 2023 effective date of the digital asset...more

The Year in Tax Law – 2022 Popular Reads on JD Supra

Beacon Insights by JD Supra on 1/5/2023

A look at some of the most widely read tax-related updates and commentary published on JD Supra during 2022....more

2022 Year-End Estate Planning Advisory

Katten Muchin Rosenman LLP on 11/18/2022

During 2022, COVID-19, the war in Ukraine, global inflation, the Tax Cuts and Jobs Act (TCJA), the uncertainty about the Build Back Better Act (BBBA), the Corporate Transparency Act (CTA), and the Inflation Reduction Act...more

Today in Tax: How NFT Sellers Can Prepare for State Taxes

Miller Nash LLP on 9/27/2022

Pennsylvania and Washington became the first two states to offer official guidance on how their existing tax regimes apply to nonfungible token (NFT) transactions. Their approaches offer two blueprints for other states to...more

The Inflation Reduction Act — Incentives for Clean Motor Vehicles and Refueling Property

Orrick, Herrington & Sutcliffe LLP on 8/8/2022

The Inflation Reduction Act of 2022 (the “IRA”) released by U.S. Senate Democrats on July 27, 2022 would, if enacted, provide a number of financial incentives to encourage the purchase of electric and hydrogen fuel cell...more

Kazakhstan Stock Exchange: Significant Change to Taxation of Dividends on Certain Shares

Morgan Lewis on 7/25/2022

The rules for taxation of dividends in respect of shares that are included in the official listing of a stock exchange in Kazakhstan will significantly change as of 1 January 2023....more

States Turning Eyes to Taxation of Cryptocurrency and Non-Fungible Tokens (NFTs)

Cadwalader, Wickersham & Taft LLP on 7/21/2022

As the IRS ponders its approach to taxing cryptocurrency and NFTs, states are increasingly imposing taxes on some digital asset transactions, including the use of cryptocurrencies...more

The Biden Administration Proposes Changes to the Taxation of Cryptocurrency Transactions

Proskauer - Tax Talks on 5/5/2022

On March 28, 2022, the Biden Administration proposed certain very limited changes to the taxation of cryptocurrency transactions. The proposals do not change the current treatment of cryptocurrency as property for federal...more

Cryptocurrency: The Basics of Tax Treatment and Recognition

Gray Reed on 4/1/2022

Cryptocurrencies might, simplistically, be defined as virtual currencies that use cryptography to secure transactions which are digitally recorded on a widely distributed ledger. The ledger technology uses independent...more

New Crypto Reporting Requirements Aim to Address Tax Gap

Kohrman Jackson & Krantz LLP on 2/11/2022

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

Fiscalité internationale : Décisions de la Cour suprême du Canada

Blake, Cassels & Graydon LLP on 1/6/2022

La Cour suprême du Canada (la « CSC ») a récemment rendu d’importantes décisions dans deux différends qui portaient sur des questions de fiscalité internationale. Dans l’affaire Canada c. Alta Energy Luxembourg S.A.R.L., 2021...more

International Tax Issues at the Supreme Court of Canada

Blake, Cassels & Graydon LLP on 12/20/2021

The Supreme Court of Canada (SCC) recently released two important decisions relating to international tax issues. The SCC provided meaningful guidance on the interpretation of one of Canada’s bilateral tax treaties and the...more

Internal Revenue Service Announces Changes to Income Thresholds for 2022 Federal Income Tax Brackets

Lasher Holzapfel Sperry & Ebberson PLLC on 11/15/2021

The IRS has announced it will be adjusting income thresholds for federal income tax brackets in 2022. Typically, the IRS raises thresholds to keep pace with consumer prices, however October’s year-over-year increases of...more

Estate Planning Provisions of the New Tax Plan

Blank Rome LLP on 9/20/2021

On Monday, September 13, 2021, the House Ways & Means Committee released a draft tax plan which provides the clearest direction to date on how Democrats intend to use the estate and gift tax regimes to pay for part of the...more

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on 9/7/2021

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Tax and Estate Planning for Cryptocurrency

Chambliss, Bahner & Stophel, P.C. on 8/17/2021

In the past year, the global market capitalization of cryptocurrency has grown exponentially, reaching a high of $2.56 trillion on May 11, 2021. Coinbase, the largest cryptocurrency exchange, has more than 68 million verified...more

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