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November 20, 2024
Shrinking Carried Interest Loophole Under Attack Again
Should We Address the Big Red Elephant in the Room?
UK Autumn Budget 2024 – Key Tax Measures
Frozen Crypto
REIT PLR: No Assets? No Income? No Problem.
October 23, 2024
The Tax Reform Ghost Returns for the Expiring TCJA Provisions
Treasury and IRS Release Proposed Corporate Alternative Minimum Tax Regulations
Extracting Value
Charging Ahead or Stalling Out? Clean Energy Credits Await Key Guidance
First Stand-Alone Crypto Tax Fraud Case Leads to Guilty Plea
September 25, 2024
Presidential Candidates’ Tax Proposals Diverge on the Road to November
Basket Contract Listed Transactions
Not Yet Fixed in Place
Back in Session: Energy Tax Credits
August 28, 2024
Treasury Finalizes “Killer B” Regulations with Few Adjustments
GE Financial Investments
: What Determines Residency?
Give Unto Caesar – Crypto?
Recognising “Imported Losses” Under the UK’s Loan Relationship Rules
Energy Tax Credit Sales Stay Fully Charged Despite Uncertain Road Ahead
Liberty Global Appeals Economic Substance Doctrine Ruling
July 24, 2024
Supreme Court Overruling of
Chevron
Fuels Regulatory Uncertainty
Finally Final Crypto Reporting Regulations
IRS Private Letter Ruling Says CPACE Loans Qualify for REMIC Transactions
IRS Aims to End Abusive Basis-Shifting Transactions
Burlington
: Good News for the Secondary Debt Market
The Supreme Court Has Saved the Tax Code for Now and Left Room for
Moore
June 26, 2024
Cadwalader Speaks With Law360 About New IRS Spinoff Guidance
Everything You Need to Know About Energy Tax Credit Sales
Ascertaining the Purpose of a Loan Relationship
Crypto Red Flags For Financial Institutions
What’s in a Name? When Does an Option Agreement Not Grant an Option?
IRS Kicks Substantial Equivalence Test Down the Road Again
Aftermath of YA Global: A Call for Procedural Clarity for Section 1446 Withholding Tax
May 22, 2024
IRS Distributes New Ruling Requirements for Corporate Spin-Off Transactions
Crypto: Give Unto Caesar What Is Caesar’s
Complex Borrowing and Group Structures
Final Rules on Energy Tax Credit Sales Confirm All Systems Go
EU State Aid Litigation Casts a Long Shadow
Reaction to Donor-Advised Fund Proposed Regulations Prompts IRS Hearing
Getting Technical with Partnership Termination Rule
Mixed Opinions on Penalty Relief for Corporate AMT Taxpayers
April 24, 2024
Proposed Regulations for Buyback Tax Hit LBOs, Preferred Stock but Spare Tier 1 Capital
Should I Stay or Should I Go? Hedge Funds: Crypto and State Tax
Tax Insurance May Boost the Market for Energy Tax Credits
UK Guidance on Capital-Raising Arrangements
Location, Location, Location: New York’s Apportionment Rules for Investment Managers
“Ephemeral” Payments and Beneficial Entitlement
March 27, 2024
Balancing Uncle Sam’s Checkbook: Biden’s Tax Proposals
UK Spring Budget 2024 – Key Tax Measures
IRS Hints at Revolution in Tax-Free Spin-Off Rules, Ruling Practice
It’s Raining Crypto Bots on the IRS
Energy Tax Credit Guidance Continues to Blossom
Another Step Nearer for CARF in the UK
February 28, 2024
U.S. Deploys Pincer Maneuver on Perceived Crypto Abuses
American Cousins: HMRC Revisits
Anson
IRS Releases Proposed Donor-Advised Fund Regulations
Liberty Global to Appeal Its Foreign Tax Credit Tax Court Loss
January 25, 2024
Treasury Cries “Uncle” to Crypto Industry: Crypto Reporting Delayed
Green Means Go for Energy Tax Credit Sales
Missing the Target
A Worthwhile Proposal for Worthless Debt
Guidance on Limited Partnership Exception May Include a Functional Analysis Test
ABA Tax Section Comments on Proposed Crypto Broker Reporting Regulations
Eager for
Moore
?
December 20, 2023
UK Spearheads Global Commitment to the Crypto-Asset Reporting Framework
Crossing the U.S. Trade or Business Line
Exchange Trust Certificates in REMIC Transactions Qualify as Stripped Bonds or Coupons
Beware of Monsters
Moore
Bark Than Bite? Supreme Court Weighs In
November 28, 2023
Crypto Market Participants Push Back on Proposed Crypto Reporting Regulations
A Huge Win for the Economic Substance Doctrine
Examining "Purpose"
NYSBA Tax Section’s Recommendations on the Proposed Crypto Broker Reporting Regulations
Treasury Gearing Up for Energy Tax Credit Transfers
Joint Committee on Taxation Cautions Less Is
Moore
October 25, 2023
New Proposed 'Killer B' Regulations Reduce Compliance Sting
Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme
Perfect Influence?
Entity Conversion Under State Law Is Not a Modification of Debt
Treasury Greases the Wheels on Energy Tax Credit Transfers
Guidance on Limited Partnership Exception May Be Near
September 27, 2023
Treasury Delivers Mother Lode of Tax Reporting Rules to the Crypto Industry’s Doorstep
Treasury's Recycling Bin Overflows with Comments to Their Proposed Rules on Energy Tax Credit Transfers
Tax Abolition (but of a tax not actively collected)
NIL Collectives Strike Out on Tax-Exempt Status
Over the Horizon
Liberty Global and DOJ Go Head to Head on Economic Substance Doctrine
Android Agents Dreaming of Tax Returns
August 23, 2023
IRS Holds That Crypto Staking Rewards are Taxable Income
Is Treasury Tilting at Windmills with their Proposed Rules on Clean Energy Tax Credit Transfers?
Pin-pointing Residence
Limited Partner Exception Challenged by Hedge Fund Legend
Hargreaves Property
: What Does the Latest Decision Mean for UK Withholding Tax?
CMBS Loan Modifications
July 27, 2023
Congress Getting in on
Barbenheimer
Action, Goes for Crypto Tax Double Feature
NYSBA Tax Section Recommends Guidance on NFTs
IRS Publishes Final Regulations on IBOR Transition for Published Rate Elections
Is There Taxation Without Realization?
Moore
May Create More Questions Than Answers
June 28, 2023
IRS Releases Proposed Rules on Selling Energy Tax Credits
Playing the Waiting Game on Crypto Tax Reporting
IRS Takes Partnership Entity-Level View on FIRPTA’s Publicly Traded Stock Exception
Court of Justice Rules on UK Group Asset Transfer Rules
Pre-Closing Special Dividends: Distributions or Sales Proceeds?
May 24, 2023
Cryptocurrency Is Property Not Currency Even if Legal Tender, Per IRS
Tax Court Adopts Broad Reading of Profits Interests Safe Harbor
IRS Says Crypto Protocol Changes Are Not Taxable
Crammed Down but Not Out: HMRC Successfully Opposes Restructuring Plans
UK Tax Administration and Maintenance Day 2023 – Key Tax Consultations
April 27, 2023
Through the Looking Glass: Will a Look-Through Rule for Taxing NFTs Clarify or Further Distort?
No Need to Pretend – Just Extend – if Borrowers Ask to Delay Repayment
IRS Gets Serious About Digital Asset Reporting by Individuals
A Toothless Tax Avoidance Scheme: M Northwood v HMRC
March 21, 2023
Potential Constitutional Challenge: Biden Budget Proposes Mark-to-Market for High-Net-Worth Individuals
Airing Dirty Laundry: Biden Budget Targets Crypto Wash Sales
UK Budget 2023 – Key Tax Measures
Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case
February 23, 2023
The States Come Marching In: Investors Ignore State Wealth Taxes at Their Peril
New Look-Through Rules Will Impact Foreign Investment in REITs
Case May Bring Clarity on Self-Employment Tax on Limited Partners
Saving Loans for REMICs
Good v HMRC – What Does ‘Entitled To’ Mean?
EU List of Non-Cooperative Jurisdictions Expanded
January 26, 2023
IRS Sheds Light on Harvesting Crypto Losses
Back to the Future ... Cryptocurrency Tax Reporting
Brakes Applied to a Speedy Reorganisation
Notice 2023-2 Provides Helpful Guidance Regarding the Stock Repurchase Excise Tax
UK Government Finalises Mandatory Disclosure Rules
Notice 2023-7 Provides Initial Guidance Regarding the Corporate Alternative Minimum Tax
December 15, 2022
FTX Tax Losses: The Land of Misfit Toys
On the Hunt for Financial Services (and Tax) Reforms
UK VAT Treatment of Fund Management Review Announced
UK Government Expands Assets within the Scope of the UK’s IME to Include Cryptoassets
Proposed Treasury Regulations Would Disallow Technique to Reduce Subpart F and GILTI Inclusions
Treasury Holds Fast on Centralized Partnership Audits
November 29, 2022
Cadwalader Attorneys Author Law360 Article on Crypto Staking Rewards Taxation Uncertainty
Update: OECD Crypto-Asset Reporting Framework
IRS’s Crypto John Doe Summons Expanded While Harper Fights Back
Getting the Fiats Straight: CJEU Annulled State Aid Decision against Fiat
October 20, 2022
Cadwalader Tax Attorneys Author Law360 Article on Tax Uncertainty Around Digital Assets
Sub-Participations Are VAT Exempt Under EU Law
Podcast: Tax Aspects of CRE CLO Transactions
Staking Rewards: Is IRS Digging In or Changing Its Mind?
September 22, 2022
Ethereum Merge – Soft Fork for Now?
UK Government Considers Changes to the Rules on Sovereign Immunity from Direct Taxation
Key Features and Ambiguities of the New Corporate Book Minimum Tax
Burlington Loan Management DAC: Treaty Shopping Provisions Did Not Apply
IRS Cries Uncle for the Fourth Time on the Section 871(m) Substantial Equivalence Test
August 18, 2022
Tax Provisions in the Inflation Reduction Act of 2022
Mini-Me Crypto Tax Legislation
HMRC v BlackRock Holdco 5 LLC Throws a Spotlight on UK Transfer Pricing and the ‘Unallowable Purposes’ Rule
BlueCrest Salaried Members Case: Who Is a Significant Influencer?
‘Covered Modifications’ and LSTA’s New SOFR Amendment Forms
To Elect or Not to Elect: U.S. Partners May Soon Have to Decide for Themselves Whether to File Passive Foreign Investment Company (PFIC) Elections
August 11, 2022
Senate Passes Inflation Reduction Act
July 21, 2022
States Turning Eyes to Taxation of Cryptocurrency and Non-Fungible Tokens (NFTs)
UK Government Announces DeFi Lending and Staking Consultation
Looking Forward: The IRS Denies 40/60 Treatment for Over-the-Counter Foreign Currency Options under the Mark-to-Market Rules
EU Advocate-General Opined Sub-Participation Not within VAT Exemption for Granting Credit
June 23, 2022
The Crypto Industry Is Talking Tax, and the Senate Is Listening
UK Government Considering Expansion of Investment Transactions List to Include Crypto-Assets
European Commission Consultation on EU-wide Withholding Tax System
May 25, 2022
Crypto Trading Safe Harbor – We’re On Our Own
European Parliament Draft Report on Crypto
New Proposed NOL Regulations on the Horizon
A Step Forward for a Corporate Re-domiciliation Regime for the UK
April 21, 2022
A Pocket Guide to the 2023 Budget Proposals
President Biden’s Greenbook Provides Clarity on Digital Asset Taxation
OECD Cryptoasset Reporting Framework
NYSBA Tax Section’s Crypto Recommendations
Haworth
: Residency Tie-Breaker Tests in a ‘Round the World’ Tax Scheme
March 24, 2022
Podcast: Tax Aspects of Litigation Finance
The UK Funds Review Response: Steps Forward But a Key Opportunity Missed
U.S. Executive Order on Crypto Assets Sets Policy Objectives
Measures Against Russia (Only)? UK Economic Crime (Transparency and Enforcement) Act 2022
February 24, 2022
EU’s Proposal on Implementing Pillar Two
Is Staking a Taxable Service?
UK Revenue Guidance on Cryptoasset Lending and Staking Using Decentralised Finance
Revenue Adjusted Lease Payments Are Not REIT Qualifying Income
January 28, 2022
Europe Adds Cayman Islands to 'High-Risk' List
EU Directive Targets 'Shell' Companies
Proposed Regs Affect PFIC Elections
IRS Publishes Final IBOR Transition Regulations
January 3, 2022
IRS Publishes Final IBOR Transition Regulations
December 14, 2021
Build Back Better Act: Comparison of Senate Finance Committee and House Tax Provisions
November 22, 2021
House Passes Build Back Better Act
November 10, 2021
Breaking Up: Case Study on GE’s Proposed Spin-Offs
October 28, 2021
Wyden’s Billionaires Tax
The UK’s Autumn Budget 2021 – Key Tax Measures
Practitioners Voice Concerns Over Grantor Trust Proposal
Representative Neal Proposes IRA Changes
Keep Your Eyes on Mark-to-Market
September 30, 2021
A Look at the House Ways and Means Committee’s Tax Proposals
Wyden Proposes Partnership Tax Reform
A Comparison of Recent Tax Proposals
August 27, 2021
Wyden’s Carried Interests Bill
August 24, 2021
REITs Reconfigure
Senate Democrats Pass Budget Resolution
Rationalizing Lending Authorities
Infrastructure Bill Includes Broker Crypto Reporting
Wyden Wants to Limit “Mega-IRAs”
July 27, 2021
An(other) OECD BEPS 2.0 Update
Nonresident Corporate Partner Subject to NYC Tax on Sale of Partnership Interest
Wyden Proposes Expansion of Pass-Through Deduction
A Look at the Biden Administration’s Fiscal Year 2022 Revenue Proposals
June 1, 2021
A Look at the Biden Administration’s Fiscal Year 2022 Revenue Proposals
May 26, 2021
RMTs Roll On: Case Study on AT&T’s RMT Deal with Discovery
EU’s Ambition Beyond BEPS 2.0
Legislative Crypto Proposals
IRS Announces 2021 Virtual IRS Nationwide Tax Forum
April 30, 2021
Biden Tax Proposals to Pay for the American Families Plan
A Look at the Tax Provisions in Biden’s Infrastructure Plan
IRS Issues Taxpayer-Favorable Debt Workout Ruling
Guidance Addresses BTC-to-BCH Hard Fork
Mixed Membership Partnerships: A Salient Reminder
Biden Administration’s Proposals on Pillars I & II Receive Praise and Critique Abroad
March 25, 2021
UK Proposes Securitization Tax Reform
Tax Changes in COVID-19 Relief Legislation
The Biden Administration: Key Treasury and IRS Positions
New York Proposes Stock Transfer Tax
February 25, 2021
Carried Interests in the Crosshairs (Again)
UK Asset Holding Companies: What Does the Future Hold?
Democrats Propose Mark-to-Market Tax and Increased Audits on High-Net-Worth Individuals
New York Assembly Sponsored Legislation Proposes New Tax on Mezzanine Debt and Preferred Equity
January 26, 2021
The Consolidated Appropriations Act of 2021
An About-Face on PPP Deductibility
A Peek Behind the Curtain: IRS Musings on Spinoff Ruling Procedures
IRS Finalizes Carried Interest Regulations
IRS Extends COVID-19 Forbearance Relief for REMICs and Grantor Trusts
HMRC Announces Unexpected Changes to DAC 6
January 14, 2021
IRS Extends COVID-19 Forbearance Relief for REMICs and Grantor Trusts
January 8, 2021
IRS Finalizes Carried Interest Regulations
December 22, 2020
Belgium as a New Springboard into the EU?
IRS Issues Final and Proposed PFIC Regulations
IRS Issues Final Like-Kind Exchange Regulations
IRS Finalizes Book-Tax Conformity Regulations
November 23, 2020
Bankruptcy Tax in the COVID Era
Biden’s Tax Plan
IRS Clarifies Nondeductibility of PPP Expenses
Taxing Virtual Currencies
IRS Finalizes UBTI Regulations
October 22, 2020
IRS Issues IBOR Fallback Safe Harbor for ARRC and ISDA Provisions
Caymans Removed from EU Blacklist
IRS Finalizes Foreign Partnership Withholding Regulations
IRS Finalizes T&E Expense Regulations
IRS Finalizes Inventory Sale Sourcing Regulations
October 13, 2020
IRS Issues IBOR Fallback Safe Harbor for ARRC and ISDA Provisions
October 8, 2020
Everything Old Is New Again: Bankruptcy Tax Issues from the 2008 Downturn to the 2020 Crisis
September 24, 2020
IRS Challenges Qualified Dividend Treatment
IRS Issues Final Regulations on Transfers of Partnership Interests
BEPS 2.0 – Part 4: Pillar Two
The Meaning of Words in Tax Contracts
August 25, 2020
IRS Issues Interest Barrier Regulations
Aladdin’s Magic Fails to Conjure VAT Exemption
IRS Proposes Carried Interest Regulations
BEPS 2.0 – Part 3: Pillar Two
August 4, 2020
IRS Proposes Carried Interest Regulations
July 23, 2020
IRS Proposes Like-Kind Exchange Regulations
Section 199A Guidance Benefits RIC Investors
BEPS 2.0 — Part 2: Pillar One
IRS Releases Updated Draft Partnership Return
Making the Most of Distressed Collateralized Loan Obligations
June 15, 2020
Cadwalader Cares
BEPS 2.0 — What Is It and Where Are We?
Helpful Guidance on Coronavirus-Related Trust Modifications
Saving Loans for REMICs
Loans Aren’t Securities
May 21, 2020
CARES Act: Slides Summarizing Key Tax Relief Provisions
COVID-19 Prompts DAC 6 Deferral Proposal
PPP Expenses Not Deductible
Relief for Mutual Funds and REITs
IRS Proposes UBTI Regulations
Final Debt-Equity Regulations Published
'Good' Loan Origination?
April 20, 2020
Securitization Guidance on Coronavirus-Related Forbearances
When Does a Loan Qualify for Inclusion in a REMIC in the Time of COVID-19?
Coronavirus and UK Tax
New NOL Carryback Guidance
Unrecorded Mortgages Pose Unique Issues for REMICs
The IRS CARES About Partnerships
Coronavirus Keeps Foreigners from Getting EINs
No Income, No Problem for Spinoffs
April 2, 2020
Coronavirus-Related REMIC Considerations
Tax Help in the CARES Act
CMBS Loan Modifications
Tax Filing Deadline Update
The Taxation of Distressed Mortgage Securitizations
March 23, 2020
#BrassTax: COVID-19 Edition
Tax Day Moved to July 15
A Look at the GOP's Tax Relief Proposal
Putting the Squeeze on Carried Interests
IRS Eases Some Foreign Trust Reporting Requirements
UK Budget 2020 — Key Tax Measures
Onshore CLOs May Make Sense for Insurer Investors
February 28, 2020
VAT Hits Dutch CLOs
The Taxation of Distressed Mortgage Securitizations
ICYMI: The EU “Blacklists” the Cayman Islands
#GotBrexitDone?
New Form 1040 Includes Virtual Currency Transactions
Significant Regulations Coming Soon
February 24, 2020
The EU Council’s Classification of the Cayman Islands as a “Non-Cooperative” Jurisdiction for Tax Purposes
January 22, 2020
IRS Issues Final Opportunity Zone Regulations
IRS Extends Delta-One Test for Withholding on Dividend Equivalents
IRS Adds Transition Relief for Proposed NOL Limitation Rules on Built-in Gains and Losses
A New Approach to VAT Recovery
December 11, 2019
IBOR Transition Update: The Fair Market Value Test
Guidance on Crypto Hard Forks and Airdrops
Direct Lending Under the Ireland-U.S. Tax Treaty
Close Your Eyes: Additional Thoughts on CFC Downward Attribution
Taxpayer Expectations: Legitimate or Not?
IRS Proposes Narrowing Debt Recast Rules
October 17, 2019
Transitions from IBOR to Alternative Rates Avoid Tax Under Proposed Regulations
Not Dead … But Not Quite Alive: The Resuscitation of the EU Financial Transaction Tax
New Guidance on CFC Downward Attribution Rules
U.S. Loan Origination through Irish Treaty Funds
October 10, 2019
Transitions From IBOR to Alternative Rates Avoid Tax Under Proposed Regulations
September 25, 2019
New NOL Limitations Proposed
Linda Swartz Named Influential Woman in Tax Law
Wyden Introduces “Mark to Market” Tax Bill
IRS Proposes Book-Tax Conformity Regulations
Brave New World: EU Mandatory Disclosure Rules for Cross-Border Arrangements
September 3, 2019
IRS Extends Deadline for Certain Partnership Tax Returns
IRS Continues Crypto Enforcement Efforts
Final Regulations on Partners' Shares of Creditable Foreign Taxes
UK Tax Decision Addresses Loyalty Payments
July 24, 2019
Proposed PFIC Regulations for Foreign Insurance Companies
Carried Interests Back in the Crosshairs
Jersey SPV = UK Tax Resident: The
Development Securities
Case
Proposed Regulations on Endowment Tax
June 27, 2019
Time Runs Out for Retroactive Rules on Tax Reform
IRS Narrows Look-Through Rule for Related CFCs
IRS Makes It Harder for Entities to Get a TIN
No Charitable Deduction for State Tax Payments
The Danish Cases on Beneficial Ownership and Abuse of Rights
May 23, 2019
The Disappearing Income Requirement for Spinoffs
IRS Issues Proposed Regulations on Transfers of Partnership Interests
New Proposed Regulations on Opportunity Zones
April 26, 2019
Is the Revenue Requirement Being Spun Away?
UK Real Estate Update
SFIG Sends LIBOR Tax Letter to Treasury
OZone Alert
March 21, 2019
IRS Eliminates TIN Disclosure Requirement for Partnership Representatives and Designated Individuals
Escape from New York? Not So Fast
'GILTI' Reprieve: Electing Individuals Owning CFCs Eligible for Deduction
There’s No Accounting for Choice:
Smith and Nephew Overseas Limited and Others v HMRC
No Relief for RICs Wishing to Own Commodity-Linked Notes
February 14, 2019
Tax Breaks for Lending Businesses
Ripple Effect from Proposed Regulations for CFCs
Post-Tax Act Distress
Squeezing Until the Pips Squeak: The UK Government’s Reinstatement of Crown Preference
Got Crypto? IRS Ramping Up Enforcement Efforts
January 17, 2019
A One-Year Retrospective on Tax Reform
Have You Updated Your Partnership Agreement Yet?
New UK Rules on Hybrid Capital Instruments
In Case You Missed It: The Taxation of CRE-CLOs
IRS Proposes Regulations on Dispositions of Partnership Interests by Foreign Partners
December 12, 2018
Taxing Times: The Death of LIBOR
Treasury Proposes Interest Expense Regulations
Extension of a Derivative as a Taxable Exchange
Case Study: Zayo Taxable Spin-Off and REIT Conversion
Coming Soon: Proposed Partnership Withholding Rules
November 15, 2018
Welcome to BrassTax
Guarantees by CFCs
Debt Exchanges in Spin-Offs
Heard on the Street: Self-Employment Tax Audits
UK Budget 2018 — Key Tax Measures
Land of Opportunity
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