Tax News
Bringing you the latest tax and accounting updatesIRS – Tax Tips
- UK Mini Budget 2022by Richard Miller, Emma C. McDonnell and Robert E. Gaut on September 23, 2022 at 4:50 pm
UK Mini Budget 2022 The Chancellor today unveiled the UK’s 2022 Growth Plan which has been described as being “the biggest package of tax cuts in generations”. We have summarised here the tax changes that we think will be of interest to our client base. UK corporation tax: the main corporation tax rate that was...… Continue Reading
- President Biden Signs Inflation Reduction Act into Lawby David S. Miller, Stuart Rosow, Amanda H. Nussbaum, Martin T. Hamilton, Arnold P. May, Tyler J. Moser and Rita N. Halabi on August 16, 2022 at 8:15 pm
On August 16, 2022 President Biden signed the Inflation Reduction Act of 2022 (the “IRA”) into law. The IRA includes a 15% corporate alternative minimum tax, a 1% excise tax on stock buybacks and a two-year extension of the excess business loss limitation rules. The IRA also contains a number of energy tax provisions. I....… Continue Reading
- Senate Democrats Reach Agreement to Pass Inflation Reduction Actby David S. Miller, Amanda H. Nussbaum, Stuart Rosow, Martin T. Hamilton and Rita N. Halabi on August 12, 2022 at 1:53 pm
On August 7, the Senate passed the Inflation Reduction Act of 2022 (the “IRA”). The tax provisions in the bill that was passed vary from the bill that was originally released on July 27, 2022 by Senator Joe Manchin (D-W.Va.) and Senate Majority Leader Chuck Schumer (D-NY) in four significant respects: The carried interest proposal...… Continue Reading
- A Summary of Inflation Reduction Act’s Main Energy Tax Proposalsby David S. Miller, Amanda H. Nussbaum, Martin T. Hamilton, Tyler J. Moser and Rita N. Halabi on August 8, 2022 at 2:16 pm
On August 7, the Senate passed the Inflation Reduction Act of 2022 (the “IRA”). The IRA contains a significant number of climate and energy tax proposals, many of which were previously proposed in substantially similar form by the House of Representatives in November 2021 (in the “Build Back Better Act”). Extension and expansion of production...… Continue Reading
- A Summary of Inflation Reduction Act’s Main Tax Proposalsby David S. Miller, Amanda H. Nussbaum, Stuart Rosow, Arnold P. May, Jeremy Naylor, Martin T. Hamilton and Rita N. Halabi on August 4, 2022 at 2:51 pm
On July 27, 2022, Senator Joe Manchin (D-W.Va.) and Senate Majority Leader Chuck Schumer (D-N.Y.) released the Inflation Reduction Act of 2022 (the “IRA”). The IRA contains only two non-climate and non-energy tax proposals – a 15% corporate alternative minimum tax and a provision significantly narrowing the applicability of preferential long-term capital gain rates to...… Continue Reading
- HMRC Announces Welcome Changes to the QAHC Regimeby Stephen Pevsner and Philip Gilliland on July 26, 2022 at 3:13 pm
On 20 July 2022, the UK government published draft legislation for the Finance Bill 2022-2023. Of particular interest are amendments to be made to the qualifying asset holding company (QAHC) regime that was introduced from 1 April this year. The regime is part of the UK government’s attempt to increase the attractiveness of the UK...… Continue Reading
- Summary of the Biden Administration’s Fiscal Year 2023 Green Book Tax Proposalsby David S. Miller, Amanda H. Nussbaum, Stuart Rosow, Richard M. Corn, Robert A. Friedman, Martin T. Hamilton, Arnold P. May and Rita N. Halabi on July 21, 2022 at 3:02 pm
On March 28, 2022, the Biden Administration released the Fiscal Year 2023 Budget, and the “General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals,” which is commonly referred to as the “Green Book.” The Green Book summarizes the Administration’s tax proposals contained in the Budget. The Green Book is not a proposed legislation and each...… Continue Reading
- BlueCrest FTT Decision – Salaried Member Rules and Asset Managersby Stephen Pevsner, Robert E. Gaut, Catherine Sear and David M. Ward on July 14, 2022 at 3:57 pm
The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset management limited liability partnership (LLP). BlueCrest is engaged in providing hedge fund investment management services. In...… Continue Reading
- The Biden Administration Proposes Changes to the Taxation of Partnershipsby David S. Miller, Amanda H. Nussbaum, Stuart Rosow and Rita N. Halabi on June 14, 2022 at 1:57 pm
On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a section 754 election from basis shifting to reduce taxable income;[1] and (ii) make two helpful changes to the partnership audit rules. I. Prevent...… Continue Reading
- HMRC Clarifies Application of QAHC Regime to Corporate Lending Vehiclesby Robert E. Gaut, Stephen Pevsner and David M. Ward on June 10, 2022 at 11:51 am
HMRC has recently updated the guidance relating to the UK’s new qualifying asset holding company (QAHC) tax regime which was introduced from 1 April 2022. The new guidance clarifies HMRC’s approach to whether corporate lending vehicles used by credit funds should be treated as carrying on an investment activity or a trade in the context...… Continue Reading
- A New(ish) Chemical Excise Tax Effective July 2022by Amanda H. Nussbaum, Aliza Cinamon, T.J. Ruane and Thomas Multari on May 13, 2022 at 3:18 pm
After a more than 26 year hiatus, on July 1, 2022, the Superfund chemical excise tax (the “Superfund Chemical Tax”) will again become effective. This excise tax, reinstated by the passage of the Infrastructure Investment and Jobs Act,[1] is imposed on manufacturers, producers, and importers of certain chemicals and chemical substances. As discussed below, the...… Continue Reading
- The Biden Administration Proposes Changes to the Taxation of Cryptocurrency Transactionsby Robert A. Friedman, Martin T. Hamilton, David S. Miller, Amanda H. Nussbaum, Stuart Rosow and Rita N. Halabi on May 5, 2022 at 2:30 pm
On March 28, 2022, the Biden Administration proposed certain very limited changes to the taxation of cryptocurrency transactions. The proposals do not change the current treatment of cryptocurrency as property for federal income tax purposes, and do not address any of the fundamental tax issues that cryptocurrency raise. I. Apply Securities Loan Rules to Digital...… Continue Reading
- Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stockby Dan Paulos, Amanda H. Nussbaum and Martin T. Hamilton on January 25, 2022 at 7:23 pm
On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally would treat domestic partnerships as aggregates of their partners (rather than as entities) for purposes of determining income inclusions under the Subpart F provisions applicable...… Continue Reading
- New Guidance Allows Publicly-Offered REITs and RICs to Issue up to 90% of Qualifying Dividends in the REIT or RIC’s Own Stock Through June 2022by Martine Seiden Agatston, Martin T. Hamilton, Talia Jaffe and David S. Miller on December 14, 2021 at 7:34 pm
On November 30, 2021, the IRS issued Revenue Procedure 2021-53, which temporarily allows publicly offered RICs and REITs to make distributions that are treated as dividends of up to 90% stock and the remainder in cash. Revenue Procedure 2020-19 closely follows the format of similar guidance issued during the 2008 financial crisis and in 2020,...… Continue Reading
- The Made in America Tax Plan: The Biden Administration Outlines its Tax Reform Proposalsby David S. Miller, Muhyung (Aaron) Lee, Martin T. Hamilton, Amanda H. Nussbaum and Tony Meyer, Jr. on April 5, 2021 at 10:31 pm
On March 31, 2021, the White House released a factsheet describing the “American Jobs Plan”, a $2.3 trillion proposal for infrastructure spending that also contains certain significant tax credits, and the “Made in America Tax Plan”, a tax proposal that would generate revenue to pay for the American Jobs Plan spending. The White House estimates...… Continue Reading
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...