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The IRS has introduced a significant update permitting electronic filing of Form 15620 to make an election pursuant to Section 83(b) of the Internal Revenue Code. This update modernizes the compliance requirements of Section...more
The Internal Revenue Service (IRS) continued recent improvements to the process for making elections under Section 83(b) of the Internal Revenue Code of 1986 (the Code). Until last year, an 83(b) election was made in a...more
What do you need to know about the IRS and state tax complications of offshore investments? It is common to have international investments in your portfolio, not to mention business interests. How do you navigate the...more
Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more
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
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
As employers increasingly focus on in-person office mandates, reimbursements for relocation expenses have once again become a key component of attracting top talent. If not carefully structured, however, such expense...more
New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more
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
The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more
Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more
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
On June 17, 2025, the Internal Revenue Service ("IRS") announced improvements to its Pre-Filing Agreement ("PFA") program. The IRS press release is available here. The PFA program allows Large Business & International...more
Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more
On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more
Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more
It is not uncommon for family members to lend a helping hand to one another through intrafamily loans. While loans can benefit family borrowers who may not qualify for a traditional loan or who need flexible payment...more
As investors increasingly leverage Section 1031 exchanges to defer capital gains taxes, nuanced scenarios involving interest income on exchange proceeds require careful analysis. A critical but often overlooked aspect arises...more
Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more
Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more
Companies are increasingly allowing their chief executive officers and, in certain circumstances, other executives to use corporate jets (which may be chartered flights or fractionally or fully owned aircraft) for personal...more
Spinning the Globe: When the Music Stops, the IRS Listens - Imagine standing on stage in Ibiza, Tokyo, or Miami, spinning beats to millions while pulling in seven figures per gig. That’s the reality for Dutch DJs Tiësto...more
In the years since COVID-19 shut down the country, many businesses applied for the Congressionally-authorized Employee Retention Credit (ERC), a valuable relief program created during the pandemic to support businesses who...more
Cannabis companies are increasingly taking non-280E positions on their current year federal income tax returns, while many, such as public “MSOs,” have amended prior years’ returns to reflect this position. Foley Hoag’s Tax...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