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Tax Planning Financial Services Industry Tax Liability

Vinson & Elkins LLP

Congress Begins Taking Action to Nullify Biden-Era Tax Regulations

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The opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in...more

Katten Muchin Rosenman LLP

The Salaried Members Rules and the 'Significant Influence' Test – Does the BlueCrest Case Affect Me (As a Partner) or My Firm?

Salaried Members Rules - Limited liability partnerships or "LLPs" are common corporate vehicles utilised by the financial services sector to establish UK investment management operations and other financial businesses and,...more

Gerald Nowotny - Law Office of Gerald R....

Pra Dizer Adeus (To Say Goodbye) – A Homage to Sergio Mendes and a Little Bit About Tax Planning for PPLI for Trial Lawyers

Litigation attorneys have had the ability to defer contingency fees since 1994. You are hard pressed to find another profession that has this tax advantage. Hedge fund managers have been running and winning the “Death Race”...more

DLA Piper

Belgium - VAT: New Belgian Circular Letter on the VAT Implications of Credit Insurance - Monthly Indirect Tax Alert – January 2025

DLA Piper on

Previously, for credit insurance covering the price of a supply including VAT, in so far as the credit insurer was subrogated in the rights of the insured supplier, the insurer was entitled to exercise the VAT refund right...more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Cadwalader, Wickersham & Taft LLP

Finalized Treasury Regulations Require Disclosure of Certain Micro-captive Transactions

On January 14, 2025, Treasury and the IRS published final regulations (the “Regulations”) that identify certain micro-captive insurance transactions, as well as transactions substantially similar thereto, as either listed...more

Cadwalader, Wickersham & Taft LLP

Playing the Waiting Game on Crypto Tax Reporting

As previously discussed here, the IRS published guidance in December 2022 effectively postponing the January 1, 2023 effective date for certain digital asset broker reporting rules until final regulations are promulgated. To...more

Cadwalader, Wickersham & Taft LLP

FTX Tax Losses: The Land of Misfit Toys

Reportedly, there are over a million creditors in the bankruptcy of the cryptocurrency exchange FTX and its affiliated entities. A substantial number of these FTX creditors may include U.S. retail customers who held and...more

Cadwalader, Wickersham & Taft LLP

U.S. Executive Order on Crypto Assets Sets Policy Objectives

On March 9, 2022, President Biden signed an executive order outlining the administration’s policy objectives with respect to cryptocurrencies and directs U.S. regulatory agencies to prepare various reports regarding...more

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

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

Kohrman Jackson & Krantz LLP

New Tax Rule Changes Reporting Requirements For Venmo, Paypal, Cash App

A new tax rule will see the Internal Revenue Service (IRS) gain information on income small businesses receive via transactions on popular payment applications. As of Jan. 1, 2022, businesses that accept more than $600 per...more

Foodman CPAs & Advisors

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

Stinson LLP

IRS Releases Carried Interest Proposed Regulations

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On July 31, the IRS issued proposed regulations under Section 1061 of the Internal Revenue Code further clarifying the tax treatment of carried interest and other "applicable partnership interests" (APIs)....more

Morgan Lewis

IRS Issues Proposed Regulations on Carried Interests

Morgan Lewis on

The Internal Revenue Service (IRS) and the US Treasury Department released proposed regulations (REG-107213-18) under Section 1061 on July 31 providing guidance to the holders of certain carried interests. These rules are of...more

Orrick, Herrington & Sutcliffe LLP

L'Agenzia delle Entrate commenta il regime fiscale applicabile ai proventi derivanti da prestiti erogati per il tramite di...

In sede di risposta all'Interpello n. 169 del 9 giugno 2020, l'Agenzia delle Entrate ha commentato il regime fiscale applicabile ai proventi derivanti da prestiti erogati per il tramite delle c.d. piattaforme di Peer to Peer...more

Akin Gump Strauss Hauer & Feld LLP

What's New in Washington - November 2019

Congress returns to Washington this week after the Thanksgiving recess to find a feast of leftover legislative items still on the table. Congress has a limited number of days remaining on the 2019 legislative calendar to...more

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