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Internal Revenue Service Financial Transactions

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Vinson & Elkins LLP

IRS, Treasury Look to Challenge So-Called Basis-Shifting Transactions, But It Won’t Be Easy

Vinson & Elkins LLP on

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...more

ASKramer Law

Taxation of Foreign Currency Transactions Part V: Hedged Executory Contracts

ASKramer Law on

What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more

ASKramer Law

Taxation of Foreign Currency Transactions Part IV: Hedging & Section 1.988-5(a) Debt Hedges

ASKramer Law on

Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more

ASKramer Law

Taxation of Foreign Currency Transactions Part III: Section 988 Transactions Defined, Character & Source

ASKramer Law on

Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more

Rivkin Radler LLP

Partnership Transactions Lacking Economic Substance or Business Purpose: Investor Beware

Rivkin Radler LLP on

Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than...more

Holland & Knight LLP

Not So Cryptic: IRS Increases Oversight on Cryptocurrency Income Tax Reporting Requirements

Holland & Knight LLP on

Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued last year, the IRS recently increased its oversight of cryptocurrency...more

Polsinelli

Blockchain+ Bi-Weekly - April 2024 #2

Polsinelli on

The focus in Web3 law the past few weeks has been on jurisdictional issues when litigating matters involving borderless digital asset transactions. This is expected to be an ongoing issue, as courts work through these...more

Littler

IRS Updates FAQs on 1099-Ks Used for Gig Workers and Others

Littler on

The IRS recently updated its guidance for completing Form 1099-K, used primarily by “gig” companies providing compensation using payment apps or online marketplaces and for individuals selling goods on online marketplaces...more

Cadwalader, Wickersham & Taft LLP

ABA Tax Section Comments on Proposed Crypto Broker Reporting Regulations

On December 20th, 2023, the American Bar Association Tax Section published detailed comments and recommendations (the “ABA Comments”) on the proposed crypto broker reporting regulations.  As discussed here, the New York State...more

Cadwalader, Wickersham & Taft LLP

Treasury Cries “Uncle” to Crypto Industry: Crypto Reporting Delayed

On January 16th, the IRS published Announcement 2024-4 (the “Announcement”), postponing certain reporting requirements for large crypto transactions which were set to go into effect for the 2024 tax year.  Persons engaged in...more

Foodman CPAs & Advisors

¡Libros Y Registros Adecuados Pasados Por Alto A Menudo!

La Sección 6001 del Código de Rentas Internas requiere que los contribuyentes mantengan libros y registros adecuados y “que toda persona responsable de cualquier impuesto requerido por el Código, o de su recaudación, debe...more

Foodman CPAs & Advisors

Adequate Books And Records Often Overlooked!

Internal Revenue Code Section 6001 requires Taxpayers to maintain adequate books and records and “that that every person liable for any tax imposed by the Code, or for the collection thereof, must keep such records, render...more

Gray Reed

Release the Kraken Tax Transaction Information

Gray Reed on

On June 30, 2023 the District Court in the Northern District of California granted a petition to enforce the cryptocurrency exchange Kraken to release customer information.  Specifically, Kraken was ordered to produce the...more

Cadwalader, Wickersham & Taft LLP

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.  By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

Nelson Mullins Riley & Scarborough LLP

Nelson Mullins Tax Report – Proposed Regulations on Information Reporting for Digital Asset Sales and Exchanges

On August 29, 2023, the Internal Revenue Service (IRS) issued new proposed regulations regarding reporting obligations for parties engaged in certain digital transactions.  The proposed regulations address the reporting...more

Cadwalader, Wickersham & Taft LLP

Playing the Waiting Game on Crypto Tax Reporting

As previously discussed here, the IRS published guidance in December 2022 effectively postponing the January 1, 2023 effective date for certain digital asset broker reporting rules until final regulations are promulgated. To...more

Cadwalader, Wickersham & Taft LLP

IRS Says Crypto Protocol Changes Are Not Taxable

On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more

Cadwalader, Wickersham & Taft LLP

IRS Gets Serious About Digital Asset Reporting by Individuals

Since 2019, Form 1040 has included a general question regarding the taxpayer’s cryptocurrency activity. Over the years, the IRS has modified the scope of its cryptocurrency inquiry. On the 2021 Form 1040, this question read:...more

Cadwalader, Wickersham & Taft LLP

Mini-Me Crypto Tax Legislation

Bipartisan crypto legislation was introduced by Senators Pat Toomey (R-PA) and Kyrsten Sinema (D-AZ) on July 26, 2022. If enacted, the Virtual Currency Tax Fairness Act would exclude from gross income gain on certain de...more

Proskauer - Blockchain and the Law

Congress and the IRS Make Moves to Improve Taxpayer Compliance for Cryptocurrency Transactions

IRS Commissioner Charles Rettig, testifying before Congress in April 2021, estimated the gap between taxes owed and taxes collected in the United States to be close to $1 trillion....more

Cadwalader, Wickersham & Taft LLP

Is Staking a Taxable Service?

On February 3, the Proof of Stake Alliance (“POSA”), a cryptocurrency industry association, issued a press release regarding recent developments in a cryptocurrency tax case, in which the IRS approved the tax refund sought by...more

Dechert LLP

U.S. Treasury Signals that Cryptocurrency Miners & Stakers Will Not Be Subject to Broker Information Reporting Tax Requirements

Dechert LLP on

On February 11, 2022, in a letter addressed to certain U.S. Senators, the U.S. Department of the Treasury indicated that cryptocurrency miners, cryptocurrency stakers or related hardware or software providers would not be...more

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

Kohrman Jackson & Krantz LLP

New Tax Rule Changes Reporting Requirements For Venmo, Paypal, Cash App

A new tax rule will see the Internal Revenue Service (IRS) gain information on income small businesses receive via transactions on popular payment applications. As of Jan. 1, 2022, businesses that accept more than $600 per...more

Foodman CPAs & Advisors

How Will Virtual Currency Be Taxed?

Foodman CPAs & Advisors on

Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

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