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Whiteford

Client Alert: How the “One Big Beautiful Bill Act” Impacts Employers, Employees and Contractors

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The recently enacted One Big Beautiful Bill Act (the “Act”) introduces several significant amendments to the Internal Revenue Code (“IRC”) that directly affect U.S. employers and employees. Key provisions—particularly the...more

Rivkin Radler LLP

Terminating a Trust? Don’t Forget to Consider This Tax Issue

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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

Jackson Lewis P.C.

Employers Who Administer PFML Programs Get Much-Needed Guidance from IRS

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In response to taxpayer and state government requests, including a 2024 letter from governors of nine states imploring the Internal Revenue Service (IRS) to clarify the federal tax treatment of premiums and benefits under...more

Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

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You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Foodman CPAs & Advisors

Impuestos 2023: Lo Mejor Es Prepararse Ahora

La planificación fiscal le aplica a todos. El 1/22/24, el IRS le recordó a todos los contribuyentes que comenzaran a prepararse para presentar su declaración de impuestos federales sobre la renta. Planificar con anticipación...more

Foodman CPAs & Advisors

2023 Taxes: Best To Get Ready Now

Tax planning applies to everyone. On 1/22/24, IRS reminded all taxpayers to start getting ready to file their federal income tax return. Planning ahead can help taxpayers file an accurate return and avoid delays that can slow...more

Rivkin Radler LLP

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

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Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more

Rivkin Radler LLP

Generating Tax Losses as a Hobby

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Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more

Cadwalader, Wickersham & Taft LLP

Staking Rewards: Is IRS Digging In or Changing Its Mind?

Crypto industry groups had hoped to use the tax refund case of Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.) as the vehicle to prove that staking rewards received by a crypto validator only trigger gain upon the...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the Taxation of Partnerships

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On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

McDermott Will & Schulte

Finalization of Foreign Tax Credit Rules on Disregarded Payments (Effective Retroactively)

On January 4, 2022, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) published its third set of final regulations on foreign tax credits (the “Final Regulations”) since the enactment of the Tax Cuts...more

Troutman Pepper Locke

IRS Issues New Section 382 PLR on Applying Actual Knowledge Exception

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Taxpayers looking to utilize net operating loss (NOLs) among other attributes and excess interest carryovers need to know the rules that could limit or eliminate them, including Section 382. Section 382 requires a corporation...more

Rivkin Radler LLP

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

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Taxes and Snowy Weather? How many of you awoke Saturday to find that the winter storm about which we had heard so much during the preceding days had lived up to its hype? What was your first thought? “Fudge,” right?...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

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Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Rivkin Radler LLP

Biden’s Proposed Income Tax Increases And The Sale Of The Baby Boomer Business

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“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more

Rivkin Radler LLP

New York Budget Deal Includes SALT Cap Workaround

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The New York state budget deal announced yesterday includes a workaround of the temporary federal limit on state and local tax deductions (the SALT cap). The provision was part of Gov. Cuomo’s initial budget proposal in...more

Farrell Fritz, P.C.

How Dealings Between Related Parties Doomed A Captive Insurer

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Insurance: What is it? How does it work? Assume that Acme Co is paying premiums for commercial insurance coverage to protect itself from economic losses that may arise out of various events. These premiums are deductible...more

Farrell Fritz, P.C.

Corporate Tax Hike On The Horizon: Using Reasonable Compensation To Withdraw Value

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Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...more

Schwabe, Williamson & Wyatt PC

PORTLAND OR: Metro Supportive Housing Services Tax & Preschool for All Tax

Effective January 1, 2021, Portland-metro residents and businesses need to be aware of two new taxes. The first is the Metro Supportive Housing Services Tax (“Metro Tax”), which was formerly known as Measure 26-210. The...more

McDermott Will & Schulte

New Final Regulations Revise Rules on the Application of Section 163(j) to CFCs

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

Rosenberg Martin Greenberg LLP

New Guidance from the Internal Revenue Service on Cryptocurrency: Rev. Rul. 2019-24 Clarifies the Agency’s Position on Hard Forks...

On October 9, 2019, the Internal Revenue Service (“the Service”) published further guidance regarding the tax treatment of cryptocurrency.  This marks the first time since 2014 that the Service has provided insight into the...more

Latham & Watkins LLP

The Future Ain’t What It Used to Be: New Tax Guidance Issued for Cryptocurrencies

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The IRS has published a Revenue Ruling and FAQs clarifying some long-standing virtual currency questions. On October 9, 2019, the US Internal Revenue Service (IRS) issued its first guidance on the tax treatment of...more

Troutman Pepper Locke

IRS Issues New Section 382 Private Letter Ruling On Identifying Schedule 13 Filers - TAX UPDATE Volume 2019, Issue 3

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Taxpayers looking to utilize net operating losses (NOLs), excess interest carryovers and certain other tax attributes need to be cognizant of the rules that could limit or eliminate them, including section 382. Section 382...more

Foodman CPAs & Advisors

¿Qué es un evento tributable en la moneda virtual?

Sigue habiendo dirección limitada del Tesoro de los EE.UU y el IRS sobre la Moneda virtual (MV) y los inversionistas de la MV deben proceder con cautela....more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

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“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

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