For U.S. tax purposes, digital assets are considered property, not currency. A digital asset is stored electronically and can be bought, sold, owned, transferred, or traded. The tax definition of a digital...
Manufactured housing communities (MHCs), also commonly referred to as mobile home parks, continue to increase in popularity, while state and local regulations governing them also continue to expand. Read...
Parties come together to form joint ventures when all involved believe that they will have greater success working cooperatively on a specific project, product, or business than they would have if they...
Learn best practices for advocating on behalf of your FDA-regulated clients in light of the new legal paradigm introduced by the Supreme Court’s decisions in Loper Bright and Corner Post . Read...
Do you need to learn about potential legal and business risks stemming from the use of artificial intelligence (AI) tools to manage employee performance and make employment decisions (e.g., screening,...
The exit tax implications for certain covered expatriates in choosing to permanently leave the U.S.’s worldwide taxation system are economically unpleasant. The IRC applies an exit tax to the net unrealized gains on the covered expatriate’s worldwide assets (fair market value of the assets determined on the day prior to expatriation). I.R.C. § 877A. The rules do not require a formal sale; however, the rules deem a sale of worldwide assets at fair market value to occur, with net gain in excess of an applicable exclusion amount ($821,000 for 2023) exempt from the exit tax.
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