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Recent Release of Updated Procedures for Section 355 Private Letter Rulings

The US Department of the Treasury (Treasury Department) and the IRS recently released Revenue Procedure 2024-24 (Revenue Procedure) and Notice 2024-38 (Notice) establishing revised standards and procedures for taxpayers...more

Transitional Tax Reporting Guidance for Business Transactions Involving Digital Assets

In Announcement 2024-4, the IRS and the US Department of the Treasury stated that, until regulations are issued, taxpayers will not be required to treat digital assets received in the course of their trade or business as cash...more

Treasury Department Issues Proposed Regulations for Brokers of ‘Digital Assets’

On August 25, 2023, the US Department of the Treasury issued proposed regulations that would impose new information reporting requirements for brokers that facilitate certain transactions involving “digital assets” – if...more

IRS Releases Guidance on Cryptocurrency ‘Staking’ Rewards

On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which addresses the US federal income tax treatment of cryptocurrency units (commonly referred to as coins or tokens) that are received by...more

Banking Sector Events May Affect Qualified Small Business Stock Treatment

Startups and emerging companies that are reevaluating their cash management policies following recent events in the banking sector should be aware of the implications of such policies on qualified small business stock (QSBS)...more

Tax Implications of the Inflation Reduction Act

On August 7, 2022, the US Senate passed the Inflation Reduction Act (House Resolution 5376), which contains tax, climate and healthcare provisions. The legislation is widely expected to be passed by the House of...more

Alert: Treasury Department Issues Proposed Rules on Cloud Transactions, Other Digital Content

On August 9, the US Department of the Treasury released proposed regulations on the federal income tax treatment of “cloud transactions” and certain other transactions involving digital content (the “Proposed Regulations”)....more

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