On June 28, 2024, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued final broker reporting regulations that mandate broker reporting for centralized exchanges and hosted wallet providers, providing...more
7/5/2024
/ Brokers ,
Chevron Deference ,
Crypto Exchanges ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Wallets ,
Final Rules ,
IRS ,
Popular ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
U.S. Treasury
The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more
1/9/2024
/ Chevron Deference ,
Economic Substance Doctrine ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Moore v US ,
Oral Argument ,
SCOTUS ,
Tax Court ,
Tax Credits ,
Taxation ,
U.S. Treasury
On Friday, August 25, 2023, the U.S. Treasury Department (Treasury) released proposed regulations interpreting the broker reporting rules for digital assets that were part of the 2021 Infrastructure Investment and Jobs Act...more
On July 31, 2023, the IRS issued Revenue Ruling 2023-14, which sets forth the IRS’s position as to when certain staking “rewards” are taxable income.
The Ruling analyzes a fact pattern where a cash method taxpayer “stakes...more
On March 21, 2023, the Internal Revenue Service (IRS) announced its intent to issue guidance related to the taxation of certain types of nonfungible tokens (NFTs). Notice 2023-27 is the agency’s first published document...more
On December 23, 2022, the Internal Revenue Service (IRS) released Announcement 2023-2 in response to the new broker reporting rules that were part of the 2021 Infrastructure Investment and Jobs Act (the Infrastructure Act)....more
In the newly released Proposed Foreign Tax Credit (FTC) Regulations, Treasury provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the Final FTC Regulations that...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation -
AN EXPERIENCE UNLIKE ANY OTHER -
Find yourself on the cutting-edge of international tax law, with...more
8/31/2022
/ Continuing Legal Education ,
Cross-Border ,
Cryptocurrency ,
Enforcement ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
Multinationals ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Reform ,
Transfer Pricing ,
Webinars
On August 10, 2021, the U.S. Senate passed an infrastructure bill containing explicit rules to be inserted into the Internal Revenue Code regarding digital assets. The passage marks the first time that language on this topic...more
On March 20, 2020, Treasury and the IRS released final regulations under Section 901(m). The regulations were published in the Federal Register on March 23, and generally apply to covered asset acquisitions (CAAs) occurring...more
In 2019, we published analysis to help tech and life sciences companies navigate U.S. tax law changes, an evolving IP landscape and new privacy regulations such as the California Consumer Privacy Act. We also tracked venture...more
1/8/2020
/ ABC Test ,
California Consumer Privacy Act (CCPA) ,
Consumer Privacy Rights ,
Convertible Debt ,
Corporate Governance ,
Data Privacy ,
Debt Financing ,
Direct Listing ,
Diversity ,
Emerging Technology Companies ,
Employer Liability Issues ,
Foreign Tax Credits ,
Hiring & Firing ,
Independent Contractors ,
Intellectual Property Litigation ,
Intellectual Property Protection ,
Internal Revenue Code (IRC) ,
IRS ,
Life Sciences ,
Misclassification ,
New Guidance ,
Pharmaceutical Industry ,
Privacy Laws ,
Proposed Regulation ,
Proxy Season ,
Silicon Valley ,
Startups ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Venture Capital ,
Withholding Tax ,
Woman Board Members
The final Base Erosion and Anti-Abuse Tax regulations recently approved in T.D. 9885 generally follow the December 21, 2018, proposed regulations with a few important changes. The IRS also issued new proposed regulations at...more
12/11/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Final Rules ,
Foreign Acquisitions ,
Gross Receipts Tax ,
International Tax Issues ,
IRS ,
Net Operating Losses ,
Netting Agreements ,
Partnerships ,
Proposed Regulation ,
TLAC ,
U.S. Treasury
On October 9, 2019, the IRS released Revenue Ruling 2019-24, which provides guidance with respect to hard forks and airdrops of cryptocurrency, and new frequently asked questions (FAQs), which provide guidance on other...more
10/14/2019
/ 1099s ,
Blockchain ,
Capital Gains ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
Fair Market Value ,
Income Taxes ,
IRS ,
New Guidance ,
Peer-to-Peer ,
Popular ,
Revenue Rulings ,
Transfer Taxes ,
Virtual Currency ,
W-2
Treasury and the IRS have issued proposed regulations filling a number of gaps and providing necessary guidance on the Base Erosion and Anti-Abuse Tax (BEAT). In general, the guidance is reasonably consistent with the statute...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
12/13/2018
/ Allocation of Funds ,
Banking Sector ,
Books & Records ,
CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Foreign Banks ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
Interest Payments ,
IRS ,
Multinationals ,
New Rules ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Royalties ,
Stocks ,
Subpart F ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Returns ,
Taxable Distributions ,
U.S. Treasury
In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an amount in income under subpart F, does the subpart F inclusion increase the...more
ILM 201436047 -
In a recent memorandum, ILM 201436047 (Sept. 8, 2014), the IRS chief counsel seemingly exceeded the scope of its own regulations in advising that the amount of a CFC’s section 956 investment included...more