LB&I has announced compliance initiatives regarding the Section 965 Transition Tax, Repatriation via Foreign Triangular Reorganizations, and Virtual Currency transactions.

Key Points:

..The IRS continues its efforts to educate taxpayers regarding Section 9651 and the one-time transition tax on untaxed foreign earnings while also increasing scrutiny of cross-border triangular reorganizations.

..The IRS is doubling down on its position that virtual currency should be treated as property for federal income tax purposes and warns that there are no plans to implement a voluntary disclosure program for unreported gains.