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Articles by Justin Abodalo
The 'One Big Beautiful Bill' Act: Implications on the Municipal Bond Market
Law.com CompassLaw.com RadarVerdict SearchScholarChina Law & PracticeLegal Dictionary Click to enter your existing username and password or create a new account. Click to purchase an individual user subscription with your credit card. Expert OpinionGovernment 5 minute readAugust 21, 2025 By Justin Abodalo, left, and Alexis Jabara, right, of McNees Wallace & Nurick.
83(b) Elections Made Easy: Understanding the New IRS Form 15620 | JD Supra
What is an 83(b) Election? An 83(b) election is a valuable tax strategy for individuals who receive property, such as restricted stock or LLC ownership interests, as compensation in exchange for services. However, the property is still subject to vesting. By making an 83(b) election, the individual can lock in the tax liability at the time of transfer, which can result in significant tax savings if the property or stock increases in value over time.
New Digital World, New Category of Form 1099 | JD Supra
Under the Investment Infrastructure and Jobs Act (the “IIJ”), Section 6045 of the Internal Revenue Code was modified to include digital assets among the class of assets brokers must report information on when they facilitate transactions. With these revisions, brokers of cryptocurrencies must provide information on customers and gross proceeds. In addition, these brokers must also track tax basis and holding periods.
CTA Here to Stay? Federal District Court Rules Corporate Transparency Act Unconstitutional | JD Supra
Although the Corporate Transparency Act (“CTA”) became effective Jan. 1, 2024, in just two short months, its constitutionality was challenged in the U.S. District Court, Northern District of Alabama’s decision issued on March 1: National Small Business United v. Yellen.
New Year, New Useful Guidance: Clarification on Inflation Reduction Act’s New Excise Tax for Share Redemptions | JD Supra
This past summer under the Inflation Reduction Act, Congress enacted new Internal Revenue Code (“Code”) Section 4501, which imposes an excise tax on certain corporate redemptions or repurchases by a corporation of its own stock. Essentially, Section 4501 only applies to “Covered Corporations”, which more or less translates to corporations whose stock is publicly traded. The excise tax is calculated at 1% of the fair market value of the stock repurchased (the “Excise Tax”).
New Year, New Useful Guidance: Clarification on Inflation Reduction Act’s New Excise Tax for Share Redemptions
This past summer under the Inflation Reduction Act, Congress enacted new Internal Revenue Code (“Code”) Section 4501, which imposes an excise tax on certain corporate redemptions or repurchases by a corporation of its own stock. Essentially, Section 4501 only applies to “Covered Corporations”, which more or less translates to corporations whose stock is publicly traded. The excise tax is calculated at 1% of the fair market value of the stock repurchased (the “Excise Tax”).
PA DOR Issues Guidance On Like-Kind Exchanges | JD Supra
On September 27, 2022, the Pennsylvania Department of Revenue (“DOR”) issued a revision of Personal Income Tax Bulletin 2006-07 (the “Bulletin”), which confirms that recent Pennsylvania legislation reversed longstanding caselaw that disallowed deferral of gain recognition for like-kind exchanges. Under Act 53 of 2022, the Commonwealth now conforms with section 1031 of the Internal Revenue Code (“IRC 1031”) for Pennsylvania income tax purposes.
PA DOR ISSUES GUIDANCE ON LIKE-KIND EXCHANGES
On September 27, 2022, the Pennsylvania Department of Revenue (“DOR”) issued a revision of Personal Income Tax Bulletin 2006-07 (the “Bulletin”), which confirms that recent Pennsylvania legislation reversed longstanding caselaw that disallowed deferral of gain recognition for like-kind exchanges. Under Act 53 of 2022, the Commonwealth now conforms with section 1031 of the Internal Revenue Code (“IRC 1031”) for Pennsylvania income tax purposes.
Pennsylvania – “Open for Business” or “Open to Tax” | JD Supra
Governor Wolf and other Pennsylvania lawmakers recently passed the state budget for FY22-23 (the “Budget”). Coming in at $45.2 billion, the negotiations entailed to finalize the Budget appear to be worth the effort by having the best of both worlds- increased revenue placing Pennsylvania in a strong fiscal position without having to increase any taxes.
Pennsylvania - "Open for Business" or "Open to Tax"
Governor Wolf and other Pennsylvania lawmakers recently passed the state budget for FY22-23 (the “Budget”). Coming in at $45.2 billion, the negotiations entailed to finalize the Budget appear to be worth the effort by having the best of both worlds- increased revenue placing Pennsylvania in a strong fiscal position without having to increase any taxes.
Non-Fungible Tokens – Subject to Pennsylvania Sales and Use Tax | JD Supra
This past May, the Pennsylvania Department of Revenue issued REV-717, an updated guide for retailers on the Commonwealth’s State and Local Sales, Use and Hotel Occupancy Tax. Interestingly, the portion of REV-717 discussing computer hardware and software specifically enumerated non-fungible tokens (“NFTs”) as being subject to Pennsylvania’s sales and use tax. NFTs have recently grown in popularity due to publicity from high profile purchases by celebrities like Steph Curry and Eminem.
Non-Fungible Tokens - Subject to Pennsylvania Sales and Use Tax
This past May, the Pennsylvania Department of Revenue issued REV-717, an updated guide for retailers on the Commonwealth’s State and Local Sales, Use and Hotel Occupancy Tax. Interestingly, the portion of REV-717 discussing computer hardware and software specifically enumerated non-fungible tokens (“NFTs”) as being subject to Pennsylvania’s sales and use tax. NFTs have recently grown in popularity due to publicity from high profile purchases by celebrities like Steph Curry and Eminem.
Circle of Seasons: A Refresher on the Importance of Administrative Formalities
In Circle of Seasons Charter School v. Northwestern Lehigh School District, 273 A.3d 23 (Pa. Cmwlth.
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