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Why Law Firms Are Starting to Think Like Media Companies
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Newly published Brazilian Interpretative Act (Ato Declaratório Interpretativo) N. 7/2014 expresses the Brazilian IRS’s view regarding the tax treatment applicable to cross-border payments for the use of data centers located...more
While the use of crypto-currencies such as Bitcoin have increased in popularity in Australia there has very little legal clarification provided by regulators or legislators in relation to its legal status....more
The Consumer Financial Protection Bureau (“CFPB”) recently issued a consumer advisory summarizing the purported risks of virtual currencies, and announced that it would begin collecting complaints from the public regarding...more
Earlier today the ATO released its long awaited public guidance on the Australian tax and GST treatment of bitcoin and other crypto-currencies. This guidance was originally scheduled to be released on 30 June 2014. It was...more
In another installment of the continuing saga surrounding the shuttering of the Silk Road online marketplace and arrest of its alleged creator and operator, Ross William Ulbricht (Ulbricht), a Southern District of New York...more
INVESTMENT INCENTIVES -
Generally, Canadian companies are expected to be self-supporting, but for companies involved in export development, there are several types of investment incentive programs which are designed to...more
On June 26, 2014, the U.S. Government Accountability Office (“GAO”) released a report, entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report, delivered earlier to...more
Although the 113th Congress continues to see a dearth of legislation seeing final approval, over the past six months, Congress has managed to finalize Fiscal Year 2014 appropriations; address the Sustainable Growth Rate...more
The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more
June 30 is the deadline for taxpayers with a connection to foreign financial accounts to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). As this is the first year in which all FBARs must be...more
I have been posting a lot of FBAR-related posts lately. Here’s one more.
There has been a question whether owners of “bitcoins” and other virtual currencies that have non-U.S. aspects, are subject to annual reporting...more
In This Issue:
- New York Court Grants Airbnb’s Motion to Quash Attorney General’s Subpoena
- New York City UBT Ruling Allows Broker-Dealer Sourcing for Non-Registered Broker-Dealers
- ALJ Dismisses Action as...more
The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more
For estate planning and tax advisers, it’s important to know about all of a person’s valuable and significant assets, including digital assets, so that they can help the person properly plan ahead for incapacity, death, and...more
Recently, I had a client ask me about accepting payments in Bitcoin due to perceived reduction in transaction costs. Unfortunately, there is a recent IRS ruling that makes the future of Bitcoin as a medium of exchange...more
Bitcoin has been in the news a lot recently and most of the news has been bad, including news of the bankruptcy of Mt. Gox, formerly one of the world’s largest Bitcoin exchanges. Most recently, on May 7, 2014, the SEC issued...more
The Internal Revenue Service recently issued Notice 2014-21 to provide guidance for the tax treatment of virtual currency, such as Bitcoin. In the Notice, the IRS describes how existing general tax principles apply to...more
The primary underlying goal of the Bitcoin system – to function as the world’s first completely decentralized, untaxed, and anonymous currency system – seems to have been compromised by its own popularity. Part of JD Supra's...more
Following the recent IRS publication on the U.S. tax treatment of bitcoin activities and transactions, the CRA has issued further guidance on the Canadian tax issues arising in respect of the virtual currency....more
Because Bitcoin is fungible and greatly fluctuates in value on a daily basis, Bitcoin users will need to track their cost basis for each Bitcoin obtained and determine whether they have gain or loss on the subsequent exchange...more
In This Issue:
- FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs
- No Rule Policy on MLPs
- IRS Introduces New Grandfather Rule for Equity-Linked Instruments Under Section 871(m)
On March 25, 2014 the IRS issued Notice 2014-21, which describes how the IRS will interpret existing general tax principles to apply to transactions using “virtual currencies” such as Bitcoin. This Notice is the most recent...more
As expected, the U.S. Internal Revenue Service has provided some guidance on the U.S. tax treatment of Bitcoin.
In Notice 2014-21 (March 25, 2014), the IRS stated that Bitcoin is property and not currency for tax...more
The Internal Revenue Service has joined several other jurisdictions in publishing guidance regarding the income tax consequences of certain convertible virtual currency transactions. IRS Notice 2014-21ii clarifies that...more
On March 25, the Internal Revenue Service (IRS) issued Notice 2014-21 (notice) containing guidance and frequently asked questions relating to virtual currencies such as bitcoins. Among other clarifications, the notice states...more
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