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TOPICS

Revisiting the New Markets Tax Credit

Treasury has proposed revisions to the new market tax credit regulations to make the program more attractive to investors in non–real estate businesses in low-income communities.

Shareholder Loan Documentation

This item explores the importance of paying attention to details and following document terms for shareholder loans.

Forgivable Loans in Employment Agreements

The item examines the use of forgivable loans issued at the inception of employment, where the employee receives an upfront payment of cash and the related income arising from the forgiveness of such debt is recognized over the life of the obligation provided in the agreement.

Exchange of Shares in ISO Exercise

Under Regs. Sec. 1.6045-1(d)(2), which requires that broker statements disclose securities’ adjusted basis beginning January 1, 2011, basis tracking of ISOs is more relevant than ever.

Tax Court Determines Character, Source of Golfer’s Worldwide Endorsement Income

The Tax Court recently decided Goosen, a case with potentially far-reaching implications for foreign athletes who perform within the United States. The decision has become the leading authority for determining both the character and the source of the endorsement income earned by international athletes.

INDIVIDUALS

Current Developments in Taxation of Individuals: Part 1

This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.