On August 29, 2023, the Internal Revenue Service (IRS) published new proposed regulations on tax reporting requirements for cryptocurrency brokers. The proposed regulations build on efforts to expand IRS regulation over...more
On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which concludes that the fair market value of staking rewards received by a cash-method taxpayer is includible in the taxpayer’s gross...more
On April 21, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice memorandum (ILM 202316008), concluding that a protocol upgrade to the consensus mechanism of a cryptocurrency blockchain that did not...more
In its first published guidance addressing non-fungible tokens (NFTs), the Internal Revenue Service (IRS) released Notice 2023-27 on March 21, 2023, announcing its intent to issue guidance related to the taxation of certain...more
On January 13, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice Memorandum (CCA 202302011) concluding that taxpayers cannot claim a deduction for cryptocurrency losses that have, absent a sale or other...more
1/27/2023
/ Bitcoin ,
Blockchain ,
Cryptocurrency ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Loss Limitation Rules ,
Sellers ,
Tax Deductions ,
Tax Losses ,
Tax Returns ,
Valuation
On January 13, 2023, the Internal Revenue Service (IRS) released a memorandum (CCA 202302012) concluding that a qualified appraisal is required when a taxpayer claims a charitable contribution deduction exceeding $5,000 for...more
In the latest turn of events for the closely followed Jarrett case concerning the taxation of staking rewards, on September 30, 2022, the US District Court for the Middle District of Tennessee granted the United States’...more
OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more
8/1/2022
/ Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
Investment Partnerships ,
Proposed Legislation ,
Tax Rates
On June 7, 2022, Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) introduced the highly anticipated Responsible Financial Innovation Act (the bill), which sets out to create the first complete regulatory and...more
7/15/2022
/ Brokers ,
CFTC ,
Digital Assets ,
Disclosure Requirements ,
Investment ,
IRS ,
Lending ,
Loan Agreements ,
New Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Retirement Account Loans ,
Safe Harbors ,
Securities and Exchange Commission (SEC) ,
Taxation
On March 28, 2022, the US Department of the Treasury released the Fiscal Year (FY) 2023 Revenue Proposals and Green Book, which describes the tax proposals in the Biden administration’s FY 2023 budget (2023 Budget Proposal)....more
4/8/2022
/ Accounting ,
Biden Administration ,
Bonds ,
Digital Assets ,
Green Book ,
Internal Revenue Code (IRC) ,
IRS ,
Loans ,
Proposed Regulation ,
Securities ,
Stocks ,
Taxation ,
U.S. Treasury
Stakers—taxpayers involved in proof of stake (PoS) validation of blockchain transactions—continue to operate in uncharted tax waters. PoS blockchains represent over half of the $1.68 trillion cryptocurrency market...more