Tax Law News and Insights

On August 4, 2023, the IRS published proposed regulations that, if finalized, would identify monetized installment sale transactions as a listed transaction. Sellers, intermediaries and other involved parties would be required to report such transactions to the IRS. These proposed regulations come nearly two years after the IRS for the...

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On June 20, 2023, the Court of Federal Claims denied summary judgment to the taxpayer in Alta Wind I Owner-Lessor C, et al. v. United States ("Alta Wind (2023)"),1 the latest episode in an ongoing multifaceted dispute over the calculation of the Section 1603 grant. While the Section 1603 grant expired over a...

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A. Introduction President Joe Biden, in his State of the Union address before Congress on February 7, 2023, proposed a wealth tax on “billionaires.” The lead editorial of The Wall Street Journal for February 11-12, 2023, at p. A12, captioned “Biden's 2025 Tax Agenda” discussed the proposal and said: Start...

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