On January 4, 2022, the Treasury published final regulations on foreign tax credits (T.D. 9959). These regulations, among other things, change the rules for determining creditability of a foreign tax under Section 901 and 903 by requiring that foreign tax now meet certain attribution rules to be...
Read MorePartnerships and S Corporations with certain foreign activity or foreign owners may have a surprise in their returns this year — in the form of additional reporting via Schedules K-2 (Partners’ Distribute Share Items – International) and K-3 (Partner’s Share of Income...
Read More** Updated 11/15/21 **On November 5, 2021, Congress passed the long-awaited Infrastructure Investment and Jobs Act, which was signed by President Biden on November 15. Below is a look at the two tax-related provisions included in the Act and their potential impact.1. Crypto Asset Information...
Read MoreWe were honored again to host our annual Cohen Client Conference this past week. While the event was virtual, we had several hundred attendees join us online over two days, representing mutual funds, investment advisers, hedge funds, ETFs, digital asset funds and more. This year more than ever...
Read MoreTraditionally fund managers have avoided most illiquid investments due to their perceived misalignment with the Investment Company Act of 1940. However, in recent years there has been a convergence in asset classes in search of new investment opportunities. With that, we have seen an...
Read MoreCohen & Co’s Milwaukee office began as a natural extension of the firm’s basic tenets — one of which is empowering young leaders to take risks in an environment rich with great relationships, clients and employee talent. It was the perfect recipe for a growth story! As I...
Read MoreU.S. taxpayers who invest in debt instruments not denominated in U.S. dollars are often interested in hedging the currency exposure of these types of investments. This is commonly accomplished with an investment into a forward contract, futures contract, options contract or other instrument...
Read MoreSince the enactment of the Tax Cuts and Jobs Act of 2017 (TCJA), there has been a lot of concern about the deductibility of investment advisory fees. The TCJA repealed the miscellaneous itemized deductions for individual taxpayers’ investment advisory fees for tax years 2018 through 2025. ...
Read MoreRegulated 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 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 MoreIn July 2019, the IRS released a Chief Counsel Memorandum explaining how a corporate taxpayer should calculate their charitable contribution deduction and use charitable contribution carryovers when the corporation has current year taxable income — before using prior year net operating loss...
Read MoreAfter IRS Commissioner Charles Rettig’s comments on May 30, 2019, practitioners and investors waited anxiously for additional guidance clarifying the tax treatment of cryptocurrency. On October 9, 2019, the IRS released the much anticipated guidance in Revenue Ruling 2019-24 and an outline...
Read MoreIn early August, the IRS began issuing Notice CP2000 to advise taxpayers owning virtual currency that the income or payment information the IRS received from independent third-party sources does not match the virtual currency income information reported on taxpayers’ federal income tax...
Read MoreAs always, there is a lot going on in the tax world that impacts businesses and their owners, this year in particular due to the Tax Cuts and Jobs Act. It was my privilege to again serve as editor of the AICPA’s Tax Adviser August Tax Clinic, a special section in the professional journal...
Read MoreInformation Release 2019-132, issued on July 26, 2019, advises virtual currency owners to expect a letter providing information on how to pay back taxes through filing amended returns. Virtual currency investors were identified through ongoing enforcement actions, including the summons on the...
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