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
The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more
8/29/2024
/ Anti-Money Laundering ,
Brokers ,
Digital Assets ,
Fair Market Value ,
Final Rules ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Popular ,
Reporting Requirements ,
Stablecoins ,
Tax Code ,
Tax Planning
The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more
Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...more
The IRS released a draft of a new tax form, Form 1099-DA, that brokers will use to report proceeds from certain digital asset transactions. The draft Form 1099-DA can be found on the IRS website and below. The effective date...more
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
Memorandum to our Investment Management Clients and Friends -
The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more
12/5/2023
/ Audits ,
Cross Motions ,
Fund Managers ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
IRS ,
Limited Partnerships ,
Motion for Summary Judgment ,
Self-Employment Tax ,
Tax Court
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