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Today in Tax: The Billionaire Minimum Income Tax and Cryptocurrency Tax Provisions in Biden’s 2023 Budget Proposal
Mar 29, 2022
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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. The Billionaire Minimum Income Tax in Biden’s 2023 Budget Proposal Biden’s proposed “top-up” tax on wealthy individuals would ensure that households worth more th...
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Today in Tax: New Positions on Taxation of “Staking” Rewards; New Reporting Requirements for Foreign Tax Matters
Mar 11, 2022
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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Jarrett Case Raises New Questions on How to Report Cryptocurrency “Staking” Rewards While the IRS has not specifically addressed the taxation of staking rewards,...
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Today in Tax: IRS Introduces Fast-Track Process for Obtaining Letter Rulings
Feb 28, 2022
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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. IRS Introduces Fast-Track Process for Obtaining Letter Rulings Corporate reorganizations and spin-off transactions are transactions where there is often...
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Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies
Feb 14, 2022
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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax regime. Importantly, while...
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Today in Tax: Financial Contract Modification and Foreign Tax Credits
Jan 19, 2022
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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Transition rules allow opportunity to avoid taxable income when modifying financial contracts from IBOR to another metric Contracts dependent on a discontinued in...
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Today in Tax: Eligibility of Electronic Services Income for FDII Deduction
Jan 12, 2022
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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation. In late 2017 the Tax Cuts and Jobs...
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