On May 12, 2025, Republicans in the House of Representatives introduced the One, Big, Beautiful Bill of 2025 (the “House Bill”). The House Bill comes out of the House Ways and Means Committee after weeks of internal drafting...more
5/19/2025
/ Estate Planning ,
Income Taxes ,
Investment Management ,
Pass-Through Entities ,
Proposed Legislation ,
State Taxes ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Trusts
Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more
2/24/2025
/ Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Repeal ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
U.S. Commerce Department
On February 6, 2025, Democratic Senators and Representatives proposed the Carried Interest Fairness Act, which would treat carried interest as ordinary income. Additionally, on the same day President Trump met with...more
2/11/2025
/ Capital Gains ,
Carried Interest ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
Investment Funds ,
IRS ,
Private Equity ,
Tax Credits ,
Tax Liability ,
Tax Planning ,
Tax Reform
Crypto tax policy continues to move forward, domestically and internationally. Domestically, the IRS seeks comments on the new Form 1099-DA. Internationally, the Organization for Economic Co-Operation and Development (“OECD”)...more
10/17/2024
/ Criminal Investigations ,
Cross-Border ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
FACTA ,
Income Taxes ,
IRS ,
OECD ,
Reporting Requirements ,
Tax Crimes
Tax reform, like spring, is in the air. The Biden Administration recently released its fiscal year 2025 revenue proposals, known as the annual “Greenbook.” The Greenbook’s 250+ pages of tax reforms include six potential...more
4/24/2024
/ Asset Tokens ,
Biden Administration ,
Bitcoin Mining ,
Capital Losses ,
Digital Assets ,
Financial Institutions ,
Income Taxes ,
Lending ,
Reporting Requirements ,
Tax Reform ,
Wash Sale Rules
Tax evasion is as old as tax collection, so it is no surprise that there is tax evasion related to crypto. In a recent case, United States v. Frank Ahlgren III, Federal prosecutors allege that between 2017 and 2019, the...more
The Internal Revenue Service (“IRS”) issued an announcement that it is delaying implementation of reporting obligations for businesses that accept large amounts of digital assets. This SKrypto Blog Post summarizes cash and...more
The IRS published guidance on the federal income tax treatment of staking income in Revenue Ruling 2023-14. Consistent with its prior ruling on hard forks, the IRS maintains that taxpayers realize taxable income when he or...more
The Internal Revenue Service released Notice 2023-27 (the “Notice”), providing guidance on the federal tax treatment of nonfungible tokens (“NFTs”). In a prior SKRYPTO blogpost, we noted that investors selling NFTs could be...more
This Memorandum highlights several important U.S. federal income tax developments in the summer of 2022, including: (i) the Supreme Court agreeing to hear an FBAR penalty case, (ii) the Internal Revenue Service (“IRS”)...more