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DLA Piper

Senate Tax Bill: Key Points for the Investment Funds Industry

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The US Senate released a draft tax bill (Senate Tax Bill) on June 16, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management community, with a focus on how the Senate Tax Bill...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

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On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

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Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Cadwalader, Wickersham & Taft LLP

Presidential Candidates’ Tax Proposals Diverge on the Road to November

The outcome of the upcoming elections is likely to significantly impact future tax legislation.  Notably, many tax provisions enacted under prior tax legislation, commonly called the Tax Cuts and Jobs Act (the “TCJA”), will...more

Cadwalader, Wickersham & Taft LLP

Give Unto Caesar – Crypto?

On June 25, 2024, Congressman Matt Gaetz (R-FL) introduced H.R. 8822 (the “Bill”), which would add Section 6316A to the Code, allowing individuals to pay their federal income tax using Bitcoin. According to Gaetz, “enabling...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

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How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Cadwalader, Wickersham & Taft LLP

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.  By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

Proskauer - Blockchain and the Law

Congress and the IRS Make Moves to Improve Taxpayer Compliance for Cryptocurrency Transactions

IRS Commissioner Charles Rettig, testifying before Congress in April 2021, estimated the gap between taxes owed and taxes collected in the United States to be close to $1 trillion....more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

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On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Stinson LLP

NIIT Expansion Under Proposed Build Back Better Act Includes Subtle Tax Increase on Sales of Private Businesses

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In general, tax experts were pleased that the Build Back Better Act, passed recently by the U.S. House of Representatives, did not include many of the tax increases previously proposed by the Biden Administration. ...more

Foodman CPAs & Advisors

How Will Virtual Currency Be Taxed?

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Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

Foster Garvey PC

School is Back in Session and the CAT is Among the Most Popular Courses

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What We Learned from one of the Oregon Department of Revenue’s Town Hall Meetings - Over the past few months, we have written extensively on the blog about Oregon’s new Corporate Activity Tax (the “CAT”). As announced in...more

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