Gray Reed Tax Planning Partner Austin Carlson will be speaking about 1031 exchanges on a webinar hosted by ROI-Muse’s Commercial Investors & Brokers Alliance.
Scheduled for September 20, 2024, at 10 am CST, the webinar will provide a top ten rundown of tips and traps related to 1031 exchanges. During the webinar, Austin will discuss:
U.S. persons who make outbound investments in foreign corporations often have thorny federal reporting obligations. In addition to the commonly filed IRS Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, these taxpayers may have separate requirements to file an IRS Form 926, Return of a U.S. Transferor of Property
In one of my favorite legal movies, A Few Good Men, the lack of evidence on a particular point is brought up when Demi Moore’s character says to Tom Cruise’s character that he knows that something is true. Tom Cruise’s character then exclaims “it doesn’t matter what I believe, it only matters what I can
Disagreements happen. In the corporate context, one or more shareholders may share a different vision for the company than the other shareholders. Or, there may be acrimony amongst the shareholders for other reasons, as can often happen with family-run businesses. Regardless of the reason, sometimes shareholders simply want out.
Fortunately, the corporate income tax laws
Through their leadership positions with the State Bar of Texas Tax Section, Gray Reed partners Joshua Smeltzer and Matt Roberts recently submitted comments to the Treasury and IRS related to proposed regulations on foreign trusts and gifts, including applicable information return reporting. Joshua serves as a Council Member of the Tax Section and Vice Chair
With the IRS ERC moratorium still in effect, employers are carefully considering their options including litigation. Recently, the IRS indicated it was prioritizing low-risk claims while flagging others as problematic. With no clear end in sight for the moratorium, some employers are now considering litigation to obtain their ERC refund.
Law360 covered the topic on
On June 20, 2024, the Supreme Court issued a narrow ruling upholding the constitutionality of the transition tax in Moore v. United States. The Court did not address issues related to pass-through taxation, realization events, and a potential future wealth tax. The ruling preserves the tax laws related to foreign corporations that were ushered in
The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them reportable transactions. A “listed transaction” is a transaction that is the same as or substantially similar to one of the types of transactions that the
Gray Reed has recently filed two significant amicus briefs challenging the Securities and Exchange Commission’s (SEC) controversial “regulation by enforcement” approach, particularly in emerging technology sectors.
The first brief was filed on behalf of the Texas Blockchain Council and the AI Innovation Association in the ongoing SEC “gag order” case before the 9th Circuit Court
Co-author Lee Bratcher, Founder and President of the Texas Blockchain Council
Cryptocurrency has grown from a niche digital curiosity to a mainstream financial instrument. With the surge in popularity and the increase in transactions involving cryptocurrencies, the IRS has intensified its focus on ensuring proper tax reporting. They have also over-corrected with guidance and rules
