Two recent federal district court decisions evaluated whether the process historically utilized by the Department of Treasury and the Internal Revenue Service (“IRS”) to issue guidance satisfied the requirements of the...more
Just 10 years ago, only your millennial, techie cousin had ever heard of, let alone purchased, any cryptocurrency. Fast forward to 2021, and the volume of cryptocurrency transactions has grown to $15.8 trillion....more
10/6/2022
/ Bitcoin ,
Blockchain ,
Common Reporting Standard (CRS) ,
Cryptocurrency ,
Digital Assets ,
Ethereum ,
FATCA ,
FIFO ,
Foreign Financial Institutions (FFI) ,
Internal Revenue Code (IRC) ,
IRS ,
OECD ,
Popular ,
Reporting Requirements ,
Virtual Currency
Recent correspondence between a group of U.S. Senators and the Department of the Treasury appears to have eased the significant concerns expressed by the digital asset sector regarding the scope of the new broker reporting...more
Through its recent passage of the Infrastructure Investment and Jobs Act (the “Act”), Congress resolved an open question regarding the extent to which cryptocurrency transactions should be subject to information reporting...more
The IRS plans to audit the wealthiest corporate, partnership, and individual taxpayers to achieve some of its main objectives in 2022.
In his recent testimony before Congress, IRS Commissioner Charles P. Rettig...more
In August, the Federal Bar Association Section on Taxation held an informative roundtable on the IRS’s new large partnership compliance or LPC program. One of the speakers, Maria Dolan with the IRS’s Large Business &...more
10/4/2021
/ Audits ,
Bipartisan Budget Act ,
Enforcement ,
FATCA ,
FDAP ,
FIRPTA ,
IRS ,
Large Business & International Division (LB&I) ,
Partnerships ,
Pass-Through Entities ,
Tax Avoidance ,
TEFRA
Our inaugural issue focuses on a truly transnational and important rule of law: the attorney-client privilege and related protections against disclosure. While this is a topic common to all areas of law, the tax arena at...more
5/7/2021
/ Attorney-Client Privilege ,
Audits ,
Cost-Sharing ,
Disclosure ,
Dual Purpose ,
Financial Reporting Council (FRC) ,
IRS ,
Litigation Privilege ,
Microsoft ,
Stocks ,
UK ,
US v Microsoft ,
Valuation
Last week the IRS issued a revenue ruling, FAQs, and a revision to draft Schedule 1 to Form 1040 regarding various aspects of virtual currency transactions. The guidance is in line with the Treasury 2019-2020 Priority...more
Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon’s victory in a major transfer pricing dispute. The decision is also a victory for taxpayers generally because of the Ninth Circuit’s...more
In a release dated September 4, 2018, the IRS reminded taxpayers that the program that allowed for reduced civil liabilities for offshore reporting violations is coming to an end on September 28. The program, generally known...more
On August 7, 2018, the Ninth Circuit panel vacated its earlier opinion in Altera v. Commissioner that, in a nutshell, had concluded that Treasury had complied with the Administrative Procedure Act (the “APA”) in issuing final...more
On December 20, 2017, both the House and the Senate passed H.R. 1 (the “Bill”), which President Trump is expected to sign by January 3, 2018. The Bill dramatically alters the U.S. approach to domestic and international...more
On November 29, 2017, the U.S. District Court for the Northern District of California dealt a partial blow to the U.S. Department of Justice and the IRS in connection with their collective efforts to enforce an expansive and...more
On December 2, 2017, the Senate passed its version of tax reform legislation (the "Senate Bill"), advancing it to the next stage.
While the House of Representatives passed its version of tax reform (the "House Bill") on...more
Last week, on October 2, 2017, the U.S. Department of the Treasury (the “Treasury”) delivered a report to President Trump that proposes substantial revisions to eight sets of controversial U.S. federal income tax regulations...more
Our 26th President Theodore Roosevelt famously contributed to the American canon the following: “No man is above the law and no man is below it; nor do we ask any man’s permission when we ask him to obey it.” The notion that...more