Federal Taxation

  • Guidance for Transferees of Partnership Interests

    By:
    Christine Piar, Managing Director of Deloitte Tax, LLP, Copyright © 2019 Deloitte Development LLC
    |
    Nov 1, 2019
    On May 7, 2019, the IRS and the U.S. Treasury department released Proposed Regulations under IRC section 1446(f) that potentially have broad application to the transfer of any partnership interest. It’s important that transferees understand in what manner and to what extent the withholding provisions could apply to them, as well as the potential consequences of noncompliance. This article focuses specifically on the effect of these regulations on the transferee of nonpublicly traded partnership interests, even when withholding does not apply.
  • Taxation of Carried Interests for Senior-Level Fund Managers

    By:
    Arthur H. Kohn, Andrew L. Oringer, and Steven W. Rabitz
    |
    Oct 1, 2019
    Carried interest arrangements have been common for years in many types of private investment funds (“Funds”), including private equity, real estate, and hedge funds. Going back a few decades, the tax analysis applicable to carried interests was highly uncertain. 
  • IRS and Cryptocurrency: Where are We Now and What Next?

    By:
    Melissa Gillespie, JD, CPA, MST
    |
    Oct 1, 2019
    Over the past few years, the IRS has been slowly issuing guidance and warnings regarding the reporting and taxation of the usage and exchanging of virtual currency. Recently, on July 26, 2019, the IRS advised those who have engaged in virtual currency usage that they have begun sending educational letters to taxpayers with virtual currency transactions who either may have failed to report income and pay the resulting tax from virtual currency transactions or did not report their transactions properly.
  • What Professionals Need to Know About the Cannabis Industry

    By:
    Zachary Gordon, CPA
    |
    Aug 1, 2019

    Cannabis is an industry that is of great interest to CPAs, finance professionals, investors, and the public at large. While many have found their way into the industry, there is still a fundamental question to be answered by each professional: should I take on this cannabis client or investment?

  • The Nuts and Bolts of an IRS Audit and the Collection Process

    By:
    Hana Boruchov, Esq., JD, and Leo Gabovich, Esq., JD
    |
    Jul 1, 2019
    The IRS audit process is rife with procedural rules to ensure taxpayers are notified before action is taken against them and they have time to respond. However, these procedures also introduce added complexity for tax professionals who may face multiple pressures—they may lack expertise in handling audit and collection matters and/or their clients may have delayed in getting them involved in the matter and deadlines are looming.
  • Overview of Current Federal Income Taxation on Cryptocurrency Transactions

    By:
    Hanni Liu, PhD
    |
    Jul 1, 2019

    Since the inception of cryptocurrency in 2009, the very concept of currency has been challenged and debated. This article explains briefly what cryptocurrency is, how it works, and the current federal income tax implications on transactions using cryptocurrency.

  • IRS Can Resume Charging PTIN User Fees—But Final Cost Still to Be Determined

    By:
    Frank G. Colella, Esq., LL.M, CPA
    |
    Jun 1, 2019

    According to the IRS 26 C.F.R. § 1.6109-2(d), “Beginning after December 31, 2010, all tax return preparers must have a preparer tax identification number or other prescribed identifying number that was applied for and received at the time and in the manner, including the payment of a user fee, as may be prescribed by the Internal Revenue Service.” However, since June 2017, the IRS has suspended this fee charged for a “practitioner tax identification number” or PTIN.

 

 
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