Tax News
Bringing you the latest tax and accounting updatesIRS – Tax Tips
- IRS Creates Standardized Form for Section 83(b) Electionsby Jesse T. Foley, Colleen Hart, Nicholas LaSpina, David Teigman, Kyle J. Litfin and Amanda H. Nussbaum on November 18, 2024 at 4:19 pm
Earlier this month, the Internal Revenue Service (“IRS”) released Form 15620, which is an approved IRS form for making Internal Revenue Code (“Code”) Section 83(b) elections. By way of background, Code Section 83(b) provides taxpayers with the ability to include the fair market value of nonvested property over the amount (if any) paid for the...
- Post Election – Expect Tax Legislationby Robert A. Friedman, Richard M. Corn, Jean Bertrand, Amanda H. Nussbaum and Martin T. Hamilton on November 13, 2024 at 12:57 pm
I. Introduction With clear Republican victories in the White House and the Senate, and a very slim majority for either side in the House of Representatives, we can expect tax legislation in the coming year. It is expected that the President elect will likely seek to enact his economic agenda as quickly as possible. While...
- Taxing carried interest in the UK: the new regime announced in the Labour government’s Autumn Budget 2024by Catherine Sear and Frazer Money on November 12, 2024 at 1:49 pm
On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to their July 2024 general election win, including in their manifesto, and HM Treasury’s (HMT) subsequent call...
- Increase in Tax Audits of Use of Private Aircraft, a/k/a “Corporate Jets”by Richard M. Corn, Robert A. Friedman, Mitchell Gaswirth, Martin T. Hamilton, Stephanie Heilborn, Malcolm Hochenberg, David S. Miller, Amanda H. Nussbaum and Jay Waxenberg on October 28, 2024 at 3:08 pm
The IRS has announced a new audit campaign targeted at the use of private aircraft, a/k/a “corporate jets”. This has been an intensifying area of focus by the IRS over the last few years as a result of recently-increased tax benefits for private aircraft. Clients who use airplanes for business and have taken advantage of...
- No Money? No Problem: Recent IRS Favorable Guidance Regarding a REIT’s First Yearby Amanda H. Nussbaum, David S. Miller, Robert A. Friedman, Jean Bertrand, Muhyung (Aaron) Lee, Martine Seiden Agatston and Thomas Multari on October 10, 2024 at 11:21 pm
On October 4, 2024, the Internal Revenue Service (the “IRS”) released Private Letter Ruling 202440007, which concluded that the lack of income and assets in the first taxable year of an entity that had elected to be treated as a real estate investment trust (“REIT”) did not cause the entity to fail to qualify as...
- California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules – Implications for Asset Managersby Robert A. Friedman, Amanda H. Nussbaum, Muhyung (Aaron) Lee, Mitchell Gaswirth and Maggie Livingstone on September 20, 2024 at 3:41 pm
On September 13, 2024, California’s Franchise Tax Board (“FTB”) released updated proposed regulations (“Draft Regulations”), which would amend the rules regarding market-based sourcing for sales other than sales of tangible personal property. These proposed rules would have a significant effect on professional service providers, including asset managers. The Draft Regulations would apply to taxable years...
- The IRS and Senator Warren Raise Concerns about Lodging and Health Care REITsby Jean Bertrand, Richard M. Corn, Robert A. Friedman, David S. Miller, Amanda H. Nussbaum, Rita N. Halabi and Maggie Livingstone on September 19, 2024 at 10:17 pm
The IRS and Senator Warren Raise Concerns about Lodging and Health Care REITs I. Introduction On September 3, 2024, Senator Elizabeth Warren (D-MA) sent a letter to the Internal Revenue Service (the “IRS”) urging it to “increase enforcement scrutiny of REITs, especially large health and hospitality REITs that may be illegally claiming significant tax breaks...
- California Franchise Tax Board (FTB) to Apply Market-Based Sourcing Rules to Nonresident Directors of California Based Corporationsby Robert A. Friedman, Muhyung (Aaron) Lee and Mitchell Gaswirth on September 11, 2024 at 11:15 pm
On Monday, September 9, 2024, the California FTB approved proposed amendments to California’s personal income tax code. This proposed rule would impose California income tax on non-resident/non-employee corporate directors receiving fees for services performed outside of California if the corporation has a commercial domicile in California (presumably because the corporation “receives the benefit of those...
- Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactionsby Richard M. Corn, Robert A. Friedman, Martin T. Hamilton, David S. Miller, Amanda H. Nussbaum and Gregory Zeien on August 21, 2024 at 6:36 pm
1. Introduction. On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term of more than a year (or that spans two taxable years), (ii) that reference a basket of assets, and (iii)...
- UK government consults on taxation of carried interestby Catherine Sear and Emma C. McDonnell on July 30, 2024 at 5:06 pm
The newly elected UK Labour government published its call for evidence (see link here) on the taxation of carried interest on Monday 29 July 2024. This consultation by HM Treasury, cautiously anticipated following statements made during Labour’s election campaign, will remain open until 30 August 2024 during which time the government has committed to discussing...
- Increase in Tax Audits of Use of Private Aircraft, a/k/a “Corporate Jets”by Richard M. Corn, Robert A. Friedman, Mitchell Gaswirth, Martin T. Hamilton, Stephanie Heilborn, Malcolm Hochenberg, David S. Miller, Amanda H. Nussbaum and Jay Waxenberg on October 28, 2024 at 3:08 pm
The IRS has announced a new audit campaign targeted at the use of private aircraft, a/k/a “corporate jets”. This has been an intensifying area of focus by the IRS over the last few years as a result of recently-increased tax benefits for private aircraft. Clients who use airplanes for business and have taken advantage of...
- No Money? No Problem: Recent IRS Favorable Guidance Regarding a REIT’s First Yearby Amanda H. Nussbaum, David S. Miller, Robert A. Friedman, Jean Bertrand, Muhyung (Aaron) Lee, Martine Seiden Agatston and Thomas Multari on October 10, 2024 at 11:21 pm
On October 4, 2024, the Internal Revenue Service (the “IRS”) released Private Letter Ruling 202440007, which concluded that the lack of income and assets in the first taxable year of an entity that had elected to be treated as a real estate investment trust (“REIT”) did not cause the entity to fail to qualify as...
- The IRS and Senator Warren Raise Concerns about Lodging and Health Care REITsby Jean Bertrand, Richard M. Corn, Robert A. Friedman, David S. Miller, Amanda H. Nussbaum, Rita N. Halabi and Maggie Livingstone on September 19, 2024 at 10:17 pm
The IRS and Senator Warren Raise Concerns about Lodging and Health Care REITs I. Introduction On September 3, 2024, Senator Elizabeth Warren (D-MA) sent a letter to the Internal Revenue Service (the “IRS”) urging it to “increase enforcement scrutiny of REITs, especially large health and hospitality REITs that may be illegally claiming significant tax breaks...
- Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactionsby Richard M. Corn, Robert A. Friedman, Martin T. Hamilton, David S. Miller, Amanda H. Nussbaum and Gregory Zeien on August 21, 2024 at 6:36 pm
1. Introduction. On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term of more than a year (or that spans two taxable years), (ii) that reference a basket of assets, and (iii)...
- Treasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to Develop Further Partnership Guidance.by Stuart Rosow, Martin T. Hamilton, Richard M. Corn and Amanda H. Nussbaum on June 21, 2024 at 2:59 pm
On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working group” being established in the Large Business and International Division of the IRS. At the same time, Treasury and...
A Primer On Education Tax Credits
When preparing for college, students and parents can easily list the costs like tuition, fees, supplies and room and board. But do you spend enough time considering the tax benefits associated with a college education? Lucky for you there are a number of education tax...