Pursuant to statements made by IRS Commissioner Charles Rettig on May 30, 2019, much-anticipated cryptocurrency tax guidance should be released “very soon.” Rettig suggested the guidance, which would come in the form of a revenue ruling and a revenue procedure, could be released...
Read MoreOn April 17, 2019, the Department of Treasury issued the second set of proposed regulations regarding the Qualified Opportunity (QO) Zone Program. This long-awaited guidance further clarifies how to comply with the program and how to make it over some of the hurdles associated with structuring...
Read MoreThe IRS and the U.S. Department of the Treasury released round two of proposed regulations surrounding the Qualified Opportunity (QO) Zone Program today. The 169-pages of regulations address many areas, including:How businesses headquartered in designated QO Zones may benefit,The timeline for QO...
Read MoreWhile cryptocurrencies have become a popular investment vehicle, there is still much ambiguity regarding how to treat the emerging asset class for tax purposes. Taxation of cryptocurrencies is complicated at any level, be it partnership, corporation or other. However, it's also important to...
Read MoreThe IRS has announced it will begin processing paper and electronic tax returns for the 2018 tax year on January 28, but much remains to be seen about how the ongoing shutdown of the federal government will affect this year’s filings. Although the Trump administration has stated the IRS...
Read MoreThe Treasury has issued final regulations regarding the partnership representative designation and authority under the relatively new IRS partnership audit rules. These rules became effective for tax years beginning after December 31, 2017. Most importantly, the regulations confirm the...
Read MoreGenerally, a partner who sells an interest in a partnership will recognize capital gain or capital loss on the disposition. However, Internal Revenue Code Section 751 may cause an unanticipated tax consequence — the need for the partner to recognize ordinary income on the sale of the...
Read MoreThe obligation for registered investment companies (RICs) to pay foreign capital gains tax is not new by any means, but it is gaining more attention lately, making it imperative for fund management to take note. Foreign tax withholding on interest and dividends has been and continues to...
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