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Today in Tax: The Billionaire Minimum Income Tax and Cryptocurrency Tax Provisions in Biden’s 2023 Budget Proposal
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
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
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
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
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
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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