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Final Regulations Issued on Compensatory Property Transfers

Treasury recently finalized Regulations under Code Section 83, which governs the taxation of the transfer of property (such as shares of stock, partnership interests, options, or warrants) to persons...

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IRS Procures a Document Scanner, Simplifies Section 83(b) Elections

Having procured a document scanner, IRS has eliminated the requirement that taxpayers enclose Internal Revenue Code Section 83(b) elections with their income tax returns. When a taxpayer receives...

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Tax Reform Swings a Hand Ax at Carried Interests; What Does it Mean and How...

While tax reform has a long march before becoming law, the amended House of Representatives bill passed yesterday swings an ax at lower-tax-rate-capital-gain-eligible “carried” partnership interests,...

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When is a Rose Not a Rose? IRS Tries to Plug Carried Interest Loophole by...

The sweeping tax law passed in December requires partners holding some “carried interests” (partnership interests disproportionately large as compared to the relative capital contributed) to recognize...

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