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Donald Sager

Cryptocurrency Guidance, Virtual Currency FAQs Released

Cryptocurrency Guidance, Virtual Currency FAQs Released The IRS has released cryptocurrency guidance and frequently asked questions (FAQs) on virtual currency. Under the cryptocurrency guidance: a taxpayer does not have gross income from a “hard fork” of the taxpayer’s cryptocurrency if the taxpayer does not receive units of a new cryptocurrency; and a taxpayer has ordinary […]

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Donald Sager

SALT Cap Not Unconstitutionally Coercive

SALT Cap Not Unconstitutionally Coercive A district court has dismissed a lawsuit filed by four states’ against the federal government, ruling that the $10,000 state and local taxes (SALT) federal deduction cap is not unconstitutionally coercive. In 2018, New York, Connecticut, Maryland, and New Jersey filed suit against the IRS and Treasury alleging that the […]

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Donald Sager

Final Regs Revert Back to Prior Partnership Disguised Sale Rules

Final Regs Revert Back to Prior Partnership Disguised Sale Rules New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations: a partner’s share of a recourse liability of the partnership equals the partner’s share of the liability under the rules of Code […]

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Donald Sager

Proposed Regs Address Tax Implications of LIBOR Elimination

Proposed Regs Address Tax Implications of LIBOR Elimination Proposed regulations provide guidance on the potential tax consequences of replacing the London interbank offered rates (LIBORs) with a new reference rate in contracts and agreements. On July 27, 2017, the U.K. Financial Conduct Authority announced that all currency and term variants of the LIBORs may be […]

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Steve Grgas

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals Final regulations dealing with the 100 percent bonus depreciation allowance for qualified property acquired and placed in service after September 27, 2017, allow property which is constructed under a pre-September 28, 2017 binding contract to qualify for the 100 percent rate. The final […]

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