News & Analysis as of

Proposed Regulation Capital Losses

Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

Holland & Knight LLP on

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

McDermott Will & Schulte

Weekly IRS Roundup July 25 – July 29, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 25, 2022 – July 29, 2022...more

Eversheds Sutherland (US) LLP

Proposed regulations issued under section 1256 with respect to foreign currency options

Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more

McGlinchey Stafford

IRS Proposes New Like-Kind Exchange Regulations

McGlinchey Stafford on

The 2017 Tax Cut and Jobs Act (TCJA) limited like-kind exchanges occurring after 2017 to “real property held for productive use in a trade or business or investment if such real property is exchanged for real property of a...more

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