On 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...
Read MoreNew Jersey has made a number of significant changes to their tax law. Importantly, upon passing Assembly Bill A4202 last July, the state of New Jersey will soon require a combined taxpayer group to file one singular state return. The new filing requirement begins for tax years ending on or after...
Read MoreThe window for non-U.S., or foreign, investors to claim they are not subject to U.S. tax on gains stemming from the disposition of an interest in a U.S. partnership remains open. On June 11, 2019, the D.C. Court of Appeals ruled in favor of the taxpayer in Grecian Magnesite Mining Industrial &...
Read MorePursuant 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...
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