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Beneficial Ownership Information Report

Starting this year, most companies doing business in the US must report information about their beneficial owners (“BOI” or “BOI report”) to the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN). This requirement is based on the Corporate Transparency Act (“CTA”) enacted by Congress in 2021 to prevent money laundering, tax fraud, and other illicit activities. […]

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The Importance of Not Overblocking for UBIT

Taxes play an important role in the structure of a fund. There are various categories of investors that have different tax implications which will impact the structure of a tax efficient fund. One such group of investors are tax-exempt investors and the planning around Unrelated Business Income Tax (“UBIT”). A common planning strategy for UBIT is placing a blocker corporation in the structure. If the blocker corporation blocks more than the UBIT, the tax-exempt investors will have their investment earnings reduced unnecessarily. […]

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IRS Delays Implementation of $600 Threshold for Third-Party Payment platforms’ Forms 1099-K

For calendar years beginning after December 31, 2022, the third-party payment organizations are required to report payments in settlement of third-party network transactions with any participating payee that exceed a minimum threshold of $600 in aggregate payments, regardless of the number of such transactions. […]

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Klug Counsel PLLC in 2022

We hope you and your family are healthy, safe, and enjoying the holiday season to end 2022. We would like to take this opportunity to update you on exciting developments at Klug Counsel PLLC. We are excited about new members and practice areas that have been added to the firm and the creation of a related entity that will allow us to better serve our clients with accounting and finance support. […]

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Estate and Gift Tax Exemption Amount to Significantly Increase with Inflation

Prepared by Gina Lee, Senior Associate at Klug Counsel Every year, the estate and gift tax “basic exclusion amount” (commonly known as the “estate and gift tax exemption amount”) is adjusted for inflation. The Tax Cuts and Jobs Act passed in 2017 doubled the estate and gift tax exemption amount from $5 million to $10 […]

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IRS will Prioritize Enforcement Under $80B Funding: Large Business and International Division

Prepared by Arturo Meza, Foreign Associate at Klug Counsel On August 16, 2022, President Biden signed the Inflation Reduction Act into law. As part of the significant changes made by this legislation, the IRS will receive a budget increase of nearly $80 billion over the next ten years to improve four areas: enforcement, operations support, […]

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IRC §754 Election: Partner Signature No Longer Required for Partnership Basis Election

Prepared by Gina Lee, Senior Associate at Klug Counsel Treasury and the Internal Revenue Service (“IRS”) have finalized regulations that eliminate the requirement that an Internal Revenue Code (“IRC”) 754 election statement to adjust the basis of partnership property be signed by one of the partners of the partnership to be valid. To understand the […]

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Crypto Brokers and Exchanges Informational Reporting Likely Delayed

The Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) are likely to delay a January date for crypto brokers and exchanges to begin tracking and reporting data such as customers’ capital gains and losses. The move will delay when the IRS receives the same kind of data from crypto transactions as it receives for […]

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Deducting Cryptocurrency Losses

Many investors in cryptocurrencies have seen their investments lose significant value in recent months. U.S. taxpayers who have losses from their digital asset investments or have had them stolen can deduct losses. For individual taxpayers, typically the loss from the sale of crypto assets will result in a capital loss.  Capital losses can offset capital […]

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Bitcoin Miners Experience Significant Losses Over Declining Market Prices

Prepared by Chris Klug, founder of Klug Counsel The recent decline in market prices for Bitcoin has taken a toll on miners, who have seen their profits slashed.  According to data from BitInfoCharts, the average daily revenue for a Bitcoin miner has declined from around $13,000 at the beginning of 2018 to just $4,000 by […]

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