Cryptocurrency made its debut as Bitcoin in 2009 but took several years to gain mainstream attention. After growing somewhat used to the concept of cryptocurrency, new blockchain inventions have gained traction.

Despite the recent volatility and uncertainties surrounding cryptocurrency such as Bitcoin, it continues to gain worldwide attention. The draw of cryptocurrency includes simplifying international currency exchanges, reducing transaction fees, and providing a means for the instant transfer of funds.

As the war between Russia and Ukraine rages on, the conflict continues to cause widespread disruption to global supply chains and increased inflationary pressure. Along with this disruption, the war is also generating important tax implications for both individuals and businesses. A few of the tax issues that have arisen in connection with the Russia-Ukraine war include tax losses, overseas charitable giving, and workforce global mobility.

The Tax Cuts and Jobs Act of 2017 (TCJA) resulted in significant changes to the treatment of research and experimental (R&E) expenditures under Internal Revenue Code Sec. 174 that will require substantial work for many companies to implement during 2022. While it was known that a change was coming, many taxpayers continued to hope that the mandatory capitalization would be repealed or postponed.

Partnership interests (and interests in LLCs taxed as partnerships) are capital assets. Gain from the sale of capital assets is capital gain, which for individuals is taxed at preferential rates. Therefore, gain from the sale of a partnership interest must be taxed to individuals at the preferential rates applicable to capital gain. Although seemingly straightforward, there are exceptions. A partnership interest is a capital asset, except when it is not.

The article "Tax Losses Related to the Russia-Ukraine War” is featured on LexisNexis Practical Guidance. Authored by Andersen Managing Directors Ellen MacNeil, Mary Duffy and Sid Luckenbach along with Senior Manager Deanne Morton, the article details how a business can determine if a casualty loss sustained as a result of the Russia-Ukraine War qualifies for a deduction on its U.S. federal tax return.

Taxpayers with audited financial statements (AFS) have new opportunities under the final Sec. 451 regulations to defer recognizing income under the Sec. 451(b) book acceleration rule (see this Tax Release for a summary of the final Sec. 451 regulations). Those taxpayers with unbilled revenue or contract assets on the GAAP balance sheet may be able to defer such revenue for tax purposes under the new guidance.

In some families, younger generations start private equity funds and raise capital from both family and outside investors.

In trust and estate tax planning, a well understood and often used tax saving transaction is the partial interest gift discount when a non-controlling partial (or fractional) ownership interest is gifted between family members. In this case, once the fair market value of 100% of the subject real estate portfolio is established, a discount study is performed for the partial interest of the ownership amount that is transferred via a gift.