Tax Science, Computers & Technology

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Tax Talk -- Volume 7, No. 1 -- April 2014

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) - Rev....more

IRS Says Bitcoin Isn’t Money

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

Regulatory and Tax Issues Posed By Convertible Virtual Currencies

And the answer is – Property. Not surprisingly, the question is how Convertible Virtual Currencies (CVCs) such as Bitcoin should be classified for tax purposes. Given the treatment of CVCs by the Financial Crimes...more

IRS: Bitcoin Not A Currency For Tax Purposes

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

Bitcoin is property, not currency, IRS says – Notice leaves many open questions about convertible virtual currencies

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

IRS Issues Pronouncement on Virtual Currencies

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

Virtual Reality: IRS Provides Guidance on the Treatment of Bitcoin and Other Virtual Currency Transactions

On March 25, 2014, the Internal Revenue Service (IRS) issued Notice 2014-21 (the Notice), which provides guidance regarding the tax treatment of Bitcoins and other virtual currency through a series of “frequently asked...more

Estate Planning for Digital Assets

It is often said that the law lags behind technology. One area where this sentiment is particularly applicable is estate planning for digital assets. In a world where our lives are becoming ever more digital, many estate...more

Did the IRS Just Help or Hurt the Bitcoin Economy?  [Video]

Apr. 1, 2014 -- Houman Shadab, Associate Professor at New York Law School, talks with Lee Pacchia about recent developments in the bitcoin economy....more

Mining Bitcoins After the IRS 'Property' Ruling – Nothing New Under The Sun

Well settled rules that govern the taxation of transactions involving the sale or exchange of property, or the issuance of property in exchange for services, also apply to convertible virtual currency....more

IRS Issues Significant Convertible Virtual Currency Ruling – Bitcoin Community Abuzz

The IRS has issued its first major ruling on the U.S. federal tax implications of transactions in, or transactions that use, Bitcoin and other convertible virtual currencies. The ruling stresses that it relates to convertible...more

IRS Makes Bitcoins A Tax Headache

The IRS just published Notice 2014-21 which explains the IRS’ vision on how general tax principals apply to “virtual currency” transactions like Bitcoin....more

OECD Releases Discussion Draft on Tax Challenges of the Digital Economy

On March 24, 2014, the OECD released a discussion draft identifying the major tax challenges raised by the rapidly developing digital economy and summarizing several possible options to address these challenges. Comments on...more

There’s A Litigation App For That?

We were intrigued to learn that KosInteractive LLC has created the U.S. “Fed Courts” app for Android and Apple devices which contains helpful information about U.S. federal courts rules of procedure and court information. The...more

IRS Issues Significant Convertible Virtual Currency Ruling - Bitcoin Community Abuzz

The IRS has issued its first major ruling on the U.S. federal tax implications of transactions in, or transactions that use, Bitcoin and other convertible virtual currencies. The ruling stresses that it relates to convertible...more

Legal Alert: MTC to Explore Apportionment Regulations for Cloud Services, Software and Electricity

While meeting in Denver this week, the Multistate Tax Commission's Income Tax Uniformity Subcommittee advanced two separate projects to develop industry-specific apportionment regulations. One project will look at the...more

46 sites blocked, watch your banners!

The Italian tax police seized 46 websites streaming videos in breach of the copyright holders, but is also going after entities “supporting” such sites through banners published on them so starting a new approach in the fight...more

Update: EU VAT on E-Commerce

There are a great variety of electronically provided services (“e-services”) and the respective market is rapidly growing. The general definition is that e-services are services which are delivered over the Internet or an...more

The European Technology Index: Technology – An engine for growth?

In 2012, in light of the Euro crisis and uncertainty of a double dip recession, DLA Piper launched the first Tech Index survey. This was to review the perceptions and attitudes of European technology growth in light of market...more

70 Days and Counting: Clock Is Ticking to Claim Embedded Software Tax Exemption

The amount of non-taxable embedded software being taxed in California is a staggering number. While companies own assets with millions of dollars of embedded software, few companies are maximizing their property tax savings...more

Web tax into force?

The now “famous” web tax (or Google tax) on the purchase of on-line ads and sponsored links on search engines might come into force on the 1st of March 2014 having an impact on the Internet liability regime, unless the...more

The Boricua Option – The Taxation of Incentive Stock Options (ISOs) as a Puerto Rican Resident - Another Good Reason to Move to La...

Overview - Many professional living and working in Silicon Valley over the last twenty years have become very wealthy as a result of their participation in company stock options plans – qualified and non-qualified....more

Massachusetts Tax Developments - A Reed Smith Quarterly Update (4th Quarter 2013)

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll take a look back to the developments from the last quarter of 2013, and look ahead to some percolating issues at the Appellate...more

Spotlight on Tennessee: Rulings Highlight Taxable and Non-Taxable Consulting Services

Two recent letter rulings issued by the Tennessee Department of Revenue (Department) and posted on January 22, 2014 illustrate that nothing should be taken for granted in the sales and transactions taxes area when services...more

Take 5 Newsletter: Five Hot Topics for Financial Services Industry Employers

The economy may be improving, but challenges remain for employers in the financial services industry. From ever-increasing whistleblower claims to new diversity and inclusion regulations and recent IRS determinations...more

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