The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more
4/30/2025
/ Affiliates ,
Cloud Computing ,
Digital Assets ,
Final Rules ,
Foreign Affiliates ,
Income Taxes ,
International Tax Issues ,
Multinationals ,
Proposed Rules ,
Regulatory Requirements ,
Service Contracts ,
Software ,
Taxation ,
Third-Party Service Provider ,
U.S. Treasury
The U.S. Treasury Department and the Internal Revenue Service (IRS) released final broker reporting regulations with respect to DeFi on December 27, 2024, in T.D. 10021. These final regulations apply to sales of digital...more
On June 28, 2024, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued final broker reporting regulations that mandate broker reporting for centralized exchanges and hosted wallet providers, providing...more
7/5/2024
/ Brokers ,
Chevron Deference ,
Crypto Exchanges ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Wallets ,
Final Rules ,
IRS ,
Popular ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
U.S. Treasury
On March 20, 2020, Treasury and the IRS released final regulations under Section 901(m). The regulations were published in the Federal Register on March 23, and generally apply to covered asset acquisitions (CAAs) occurring...more
The final Base Erosion and Anti-Abuse Tax regulations recently approved in T.D. 9885 generally follow the December 21, 2018, proposed regulations with a few important changes. The IRS also issued new proposed regulations at...more
12/11/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Final Rules ,
Foreign Acquisitions ,
Gross Receipts Tax ,
International Tax Issues ,
IRS ,
Net Operating Losses ,
Netting Agreements ,
Partnerships ,
Proposed Regulation ,
TLAC ,
U.S. Treasury