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June 28, 2023

The much-awaited guidance on the new rules for transferring energy tax credits under the Inflation Reduction Act of 2022 provides clarification on the process and includes a few surprises.

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The expected timeline for promulgation of digital asset specific broker reporting rules remains uncertain. While crypto market participants must currently attempt to ascertain their reporting obligations under the limited guidance available, they must also be prepared to update their reporting systems to incorporate new guidance.

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A recent Chief Counsel Memorandum concludes that partnerships must determine the availability of the 5% and 10% ownership thresholds for the publicly traded stock exemption from FIRPTA tax based on the partnership’s ownership of the stock, as opposed to the relative ownership of the partners.

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Judgment clarifies the treatment of exit tax charges in the UK’s last referral to the Court of Justice of the EU.

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A recent pair of decisions by the California Office of Tax Appeals examined the tax treatment of special dividends paid in connection with the acquisition of a corporate target.

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