The Internal Revenue Service (IRS) and the Department of the Treasury issued a 282 page notice of proposed rulemaking regarding digital assets and broker reporting on Aug. 26 (the Proposed Regulations), nearly two years after...more
9/14/2023
/ Brokers ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Infrastructure Investment and Jobs Act (IIJA) ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
NPRM ,
Payment Processors ,
Popular ,
Public Hearing ,
Reporting Requirements ,
Stablecoins ,
U.S. Treasury
In a recent ruling, a California federal judge held that Kraken, an online cryptocurrency exchange program, has to turn over user information to the IRS as a result of a John Doe summons originally served on Kraken in 2021....more
The IRS and Treasury Department announced on March 21, 2023, that they intend to issue guidance providing that certain NFTs qualify as collectibles under Section 408(m) of the Code. The Notice is the first guidance issued by...more
Takeaways:
..2022 IRS Criminal Investigation Annual Report highlights significant prosecutions and identifies cryptocurrency as an area of top priority heading into 2023.
..Criminal Investigation Chief Jim Lee...more
Key Takeaways -
..A court approved the issuance of a John Doe summons by the IRS to a bank aimed at identifying individuals who are potentially avoiding their income tax obligations relating to cryptocurrency...more
9/29/2022
/ Banks ,
Bitcoin ,
Crypto Exchanges ,
Digital Assets ,
IRS ,
John Doe Investigation ,
Ponzi Scheme ,
Summons ,
Tax Avoidance ,
Tax Liability ,
Tax Returns ,
Virtual Currency
Key Takeaways:
..The law regarding computation of FBAR penalties is unclear.
..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts.
..Until the Supreme Court...more
Key Takeaways -
..Taxpayers could be criminally and civilly liable under state False Claims Act statutes for underreporting income linked to virtual currency.
..While the federal False Claims Act explicitly excludes tax...more
5/24/2022
/ Criminal Prosecution ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement ,
False Claims Act (FCA) ,
Infrastructure Investment and Jobs Act (IIJA) ,
IRS ,
Popular ,
Reporting Requirements ,
Tax Avoidance ,
Tax Fraud ,
Whistleblowers
Key Takeaways -
..The Joint Chiefs of Global Tax Enforcement (J5) issued its first intelligence bulletin providing guidance to banks, law enforcement partners and private investigators regarding indicators of potential...more
5/4/2022
/ Anti-Money Laundering ,
Banking Sector ,
Fraud ,
International Tax Authority ,
International Tax Issues ,
IRS ,
Joint Task Force ,
Know Your Customers ,
Law Enforcement ,
Market Participants ,
New Guidance ,
Non-Fungible Tokens (NFTs) ,
Popular ,
Tax Authority ,
Tax Evasion ,
Tax Fraud
On Oct. 9, the Internal Revenue Service (IRS) issued additional guidance regarding the taxation of cryptocurrency. The guidance comes more than five years after the IRS issued Notice 2014-21, the first and, until now, only...more
On March 13, the Internal Revenue Service announced that the Offshore Voluntary Disclosure Program (OVDP) will come to an end on Sept. 28, 2018. By making this announcement now, the IRS is giving taxpayers with undisclosed...more
Hedge fund managers should be aware of two recent U.S. Tax Court memorandum decisions that shed further light on when a taxpayer, such as a hedge fund, is considered to be a "trader" or "investor" for tax purposes -- a...more