IRS Tag

An Initial Coin Offering (ICO) is an event in which a new cryptocurrency project sells a portion of its cryptocurrency tokens to early enthusiasts in exchange for convertible virtual currency (e.g., bitcoin, ether) or government fiat.   ICO “tokens” or “coins” are, in essence, digital coupons...

In July 2015, the U.S. Department of the Treasury issued proposed regulations (REG-115452-14) pursuant to IRC 707(a)(2) addressing the tax treatment of certain private equity management fee waivers. Under the proposed regulations, the conversion of a management fee to a capital contribution without any “significant...

State-legal marijuana businesses operate in a twilight zone: Legal for state purposes, but illegal for federal. In this gray zone, many tax traps hide, waiting for the unwary. This article will help make you a little more wary. Let’s begin by looking at marijuana businesses from...

The omnibus spending legislation (Consolidated Appropriations Act of 2016) enacted on December 18, 2015 includes a five year extension of the investment tax credit (“ITC”) for solar and an extension for the production tax credit for wind power generation. This action provides hope that someone...

Family-owned businesses are often staples of their communities. For many owners of these types of businesses, it is desirable to sell the business to their child. This is particularly true if the child is involved in the operation of the business. Further, by selling the...

Deferring compensation is commonly used to avoid paying taxes on compensation immediately. But, under the Internal Revenue Code (IRC), deferring compensation can sometimes cause additional taxation. As a result, individuals and businesses considering deferring compensation should understand the scenarios that may trigger this tax. Deferred Compensation Deferred...

Service partnerships and fund managers best beware: The IRS has issued proposed regulations under §707(a)(2) to determine when distributions to a partner are in fact disguised payments for services. These proposed regulations target various disguised payments for services, but especially attack management fee waivers. In...

X