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Tax Law Roundup current law developments in U.S. taxation

Category Archives: Compensation

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Long-Awaited Regulations Issued on New 3.8% Net Investment Income Tax

Posted in Compensation, General, Partnership/LLC, Passthrough Entity, Real Estate

The IRS issued long-awaited proposed regulations and related FAQ guidance on the new Section 1411 3.8% tax on Net Investment Income.  The 3.8% Medicare tax is part of the tax provisions in the Affordable Care Act to pay for health care reform.  The IRS also issued proposed regulations and FAQs on the related Section 1401… Continue Reading

IRS Provides Sample 83(b) Election and Related Examples

Posted in Compensation, Corporate, Partnership/LLC

The IRS published new Rev. Proc. 2012-29, to provide both a sample election under section 83(b) and examples of the income tax consequences of making such an election with respect to compensatory stock.  It is common for a partnership or corporation to issue equity-based compensation to an employee subject to vesting and transfer restrictions.  In… Continue Reading

Proposed Regulations Address Section 83 Timing of Compensation

Posted in Compensation, General

The IRS issued new proposed regulations on the timing of taxable compensation upon the transfer of property to a service provider (e.g., compensatory stock or partnership interest).  In general, section 83 taxes the receipt of property in connection with the performance of services “in the first taxable year in which the rights of the person… Continue Reading