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
On April 10, 2025, President Donald Trump signed a joint resolution to repeal the DeFi broker reporting regulations which were finalized in December in T.D. 10021....more
On March 4, 2025, the U.S. Senate passed joint resolution S.J.Res.3, disapproving the DeFi broker reporting regulations Treasury finalized at the end of the Biden Administration. Senator Ted Cruz (R-TX) introduced the...more
3/10/2025
/ Biden Administration ,
Congressional Review Act ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Disclosure Requirements ,
Financial Services Industry ,
FinTech ,
IRS ,
Joint Resolutions ,
Regulatory Reform ,
Reporting Requirements ,
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
The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more
1/9/2024
/ Chevron Deference ,
Economic Substance Doctrine ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Moore v US ,
Oral Argument ,
SCOTUS ,
Tax Court ,
Tax Credits ,
Taxation ,
U.S. Treasury
On Friday, August 25, 2023, the U.S. Treasury Department (Treasury) released proposed regulations interpreting the broker reporting rules for digital assets that were part of the 2021 Infrastructure Investment and Jobs Act...more
On December 23, 2022, the Internal Revenue Service (IRS) released Announcement 2023-2 in response to the new broker reporting rules that were part of the 2021 Infrastructure Investment and Jobs Act (the Infrastructure Act)....more
In the newly released Proposed Foreign Tax Credit (FTC) Regulations, Treasury provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the Final FTC Regulations that...more
On August 10, 2021, the U.S. Senate passed an infrastructure bill containing explicit rules to be inserted into the Internal Revenue Code regarding digital assets. The passage marks the first time that language on this topic...more
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
Treasury and the IRS have issued proposed regulations filling a number of gaps and providing necessary guidance on the Base Erosion and Anti-Abuse Tax (BEAT). In general, the guidance is reasonably consistent with the statute...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
12/13/2018
/ Allocation of Funds ,
Banking Sector ,
Books & Records ,
CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Foreign Banks ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
Interest Payments ,
IRS ,
Multinationals ,
New Rules ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Royalties ,
Stocks ,
Subpart F ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Returns ,
Taxable Distributions ,
U.S. Treasury