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TOPICS / INDIVIDUALS

Recent developments in individual taxation

This semiannual update of recent developments in the area of individual taxation includes cases on conservation easements, discharge of student loan debt, net operating loss deductions, and real estate professional status.

Foreclosure of principal residence and DOI income

Taxpayers can exclude from gross income a discharge of qualified principal residence indebtedness before Jan. 1, 2021; under the CARES Act, certain taxpayers may also request forbearance from foreclosure on their residence.

Qualified opportunity zone rules are relaxed

In response to the COVID-19 pandemic, the IRS further postponed the 180-day deadline to invest in a qualified opportunity fund from July 15, 2020, to Dec. 31, 2020, extended other deadlines, and relaxed some qualified investment rules.

Hedging transactions: Timing of gain or loss

While the U.S. federal income tax rules generally provide comprehensive instruction on tax hedging transactions, ambiguity remains regarding the timing for transactions intended to hedge anticipated, but unfulfilled, transactions.

Final regulations govern QOZs

The IRS issued final regulations providing guidance on tax-favored investments in qualified opportunity zones (QOZs).

Recent developments in individual taxation

This semiannual update of recent developments in the area of individual taxation includes cases on hobby losses, innocent-spouse relief, material participation in a business, discharge of indebtedness, and self-employment tax, as well as IRS guidance on charitable deductions, cryptocurrency, and other topics.

Guidance explains tax treatment of cryptocurrency airdrops and hard forks

The IRS ruled that a taxpayer does not have gross income as a result of a hard fork of a cryptocurrency if the taxpayer does not receive units of a new cryptocurrency, but does have gross income as a result of an airdrop of new cryptocurrency after a hard fork if the taxpayer receives units of the new cryptocurrency.

Tax advantages of QOZ investments

Sec. 1400Z-2 offers three ways for a taxpayer to benefit from investing directly or via a passthrough entity in a qualified opportunity zone.