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Securities Internal Revenue Service Tax Planning

ASKramer Law

Tax-Loss Harvesting Part III: Investment Strategies

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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

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

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At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more

ASKramer Law

Tax-Loss Harvesting Part I: Overview

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What is tax-loss harvesting? “Tax-loss harvesting,” in its simplest form, is the sale of a capital asset at a loss to “mop up” tax that would otherwise be due on capital gain from the sale of another capital asset. Capital...more

Cadwalader, Wickersham & Taft LLP

Tax Court Calls Bluff on Hedge Fund’s Basket Option Contracts

The Tax Court recently held that a hedge fund’s basket option contracts were in substance tax ownership of the underlying basket securities. The hedge fund, through its affiliated entities, entered into 10 basket option...more

Sheppard Mullin Richter & Hampton LLP

Reminder about Annual ISO/ESPP Reporting in January 2025 and New Section 83(b) Election Form

Annual Reporting on ISO/ESPP Transactions - As originally discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require...more

ASKramer Law

Taxation of Foreign Currency Transactions Part V: Hedged Executory Contracts

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What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more

Farrell Fritz, P.C.

Responding To The Democratic Party’s Tax Plans

Farrell Fritz, P.C. on

The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

Foodman CPAs & Advisors

Who will have the last word with Virtual Currency? IRS, FinCEN, SEC, OFAC or the CFTC?

Virtual Currency (VC) investors are currently investing without clarity regarding which Government Agency(s) has the final word with respect to the treatment of VC. US Agencies: IRS, FinCEN, SEC and CFTC – have expressed...more

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