Our Federal Tax Group mines recent legislative proposals for amendments that could change the way crypto assets are reported – and taxed.
Proposed amendments to Section 6045The status of mining and staking activitiesNew proposals from the House Ways and Means CommitteeConcerns and uncertainties surround any discussion of rewriting crypto tax law
Read the full advisory here.
[...]Read more
Proposed Treasury Regulations Clarify UBTI “Silo” Rule
Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that largely follow, and partially expand, that guidance.
Special rules for investment activities, including “qualified partnership interests”Interactions with net operating loss rules, as modified by the TCJA and the CARES ActEffects on Subpart F, GILTI, and other rules
For the full advisory, click here.
[...]Read more
IRS Issues COVID-19 Forbearance Guidance for REMICs and Investment Trusts
Yesterday, our Federal Tax Group discussed a new Revenue Procedure from the IRS that provides useful real estate mortgage investment conduit (REMIC) and investment trust safe harbors for mortgage loan payment forbearances (and related modifications).
What safe harbors are available?
Which mortgage loan forbearance programs are eligible?
How are “related modifications” treated?
Alston & Bird has formed a multidisciplinary task force to advise clients on the business and legal implications of the coronavirus (COVID-19).
Read the full advisory here. [...]Read more