The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more
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
In Advice Memorandum 2010-005, the Internal Revenue Service (IRS) set out its position that “basket options” conveyed so many attributes of ownership over the securities referenced in these options to the optionee that the...more
On February 3, the Proof of Stake Alliance (“POSA”), a cryptocurrency industry association, issued a press release regarding recent developments in a cryptocurrency tax case, in which the IRS approved the tax refund sought by...more