Regulated Investment Companies (RICs) regularly invest in entities classified as partnerships for U.S. tax purposes. It is important for RIC managers to understand the different types of partnership investments, most notably whether or not a publicly traded partnership (PTP) you may be investing...
Read MoreThe IRS has released final Treasury Regulations under IRC Section 1061. The 2021 final regulations supplement the legislation enacted under the Tax Cuts & Jobs Act (TCJA) of 2017 and revise the proposed carried interest regulations issued in July 2020. The final regulations are generally less...
Read MoreThe evolution of the financial system in the United States — as well as the growing ubiquity of financial derivatives and hedging strategies — has created the need for a federal tax code that is likewise able to evolve. One such evolution found in the Taxpayer Relief Act of 1997 is...
Read MoreOn January 5, 2021, the Department of the Treasury released new final regulations pertaining to the deductibility of business interest expense under IRC Section 163(j). These regulations supplant proposed regulations issued in November 2018 and July 2020, and supplement final and proposed...
Read MoreRecent trends in the cryptocurrency marketplace have indicated an increased interest in activities connected with Proof of Stake (PoS) cryptocurrencies, whether used with the intent of receiving regular income from PoS rewards or engaging in other income generating activities in a decentralized...
Read MoreWith the presidential election only weeks away, many policy issues are being discussed, including taxes. Among their many differences, President Donald Trump and former Vice President Joe Biden have widely divergent tax proposals. Their stances could have a major impact on the amount of taxes you...
Read MorePart I of this blog post offered background on cryptocurrencies, including the different types, how to value them, and how they generally are taxed at the individual level. This post will discuss more specific strategies related to types of taxation, strategies to minimize tax and how to keep...
Read MoreOn July 31, 2020, the IRS and the Department of the Treasury issued proposed regulations under IRC Section 1061 for taxpayers that hold an applicable partnership interest (API) in connection with the performance of services. The rules, commonly known as the carried interest rules enacted as part...
Read MoreToday’s economic and regulatory environment is like no other. However, as businesses face significant challenges, there are also areas of opportunity — if you know where to look. As editor of the AICPA’s Tax Adviser August Tax Clinic, a special section in the professional...
Read MoreJoining states such as Connecticut, Louisiana, New Jersey, Oklahoma and Wisconsin, Maryland has enacted an elective pass-through entity tax to circumvent the $10,000 cap for the federal state and local tax deductions. While the IRS rendered other state and local tax workarounds ineffective, such...
Read More