President Biden signed the Inflation Reduction Act of 2022 into law on August 16, 2022, after passage with majority Democratic support in the Senate and the House. The new legislation contains significantly fewer revenue-generating tax proposals than the House-passed Build Back Better Act in November 2021. Here is a summary of the tax provisions in the Inflation Reduction Act likely to be of interest to U.S. corporate taxpayers, financial institutions, hedge funds, private equity funds, and their investors.
Bipartisan crypto legislation was introduced by Senators Pat Toomey (R-PA) and Kyrsten Sinema (D-AZ) on July 26, 2022. If enacted, the Virtual Currency Tax Fairness Act would exclude from gross income gain on certain de minimis “virtual currency” transactions where the total value and total gain is less than or equal to $50, adjusted for inflation after 2023.
A recent decision of the Upper-tier Tribunal raises questions of comparable transactions in a transfer pricing context and the application of a key anti-avoidance rule.
BlueCrest is the first case considering the UK salaried members rules relating to the treatment of partners in limited liability partnerships and the term “significant influence” in this context.
Tax practitioners welcome new LSTA forms designed to replace LIBOR with Term SOFR in credit agreements, but are advised to review all amendments.
Under Proposed Regulations, U.S. partners that indirectly hold interests in PFICs may soon be required to file their own mark-to-market, Qualified Electing Fund, and purging elections.