In its first published guidance addressing non-fungible tokens (NFTs), the Internal Revenue Service (IRS) released Notice 2023-27 on March 21, 2023, announcing its intent to issue guidance related to the taxation of certain...more
On January 13, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice Memorandum (CCA 202302011) concluding that taxpayers cannot claim a deduction for cryptocurrency losses that have, absent a sale or other...more
1/27/2023
/ Bitcoin ,
Blockchain ,
Cryptocurrency ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Loss Limitation Rules ,
Sellers ,
Tax Deductions ,
Tax Losses ,
Tax Returns ,
Valuation
In the latest turn of events for the closely followed Jarrett case concerning the taxation of staking rewards, on September 30, 2022, the US District Court for the Middle District of Tennessee granted the United States’...more
On March 28, 2022, the US Department of the Treasury released the Fiscal Year (FY) 2023 Revenue Proposals and Green Book, which describes the tax proposals in the Biden administration’s FY 2023 budget (2023 Budget Proposal)....more
4/8/2022
/ Accounting ,
Biden Administration ,
Bonds ,
Digital Assets ,
Green Book ,
Internal Revenue Code (IRC) ,
IRS ,
Loans ,
Proposed Regulation ,
Securities ,
Stocks ,
Taxation ,
U.S. Treasury
On August 1, 2021, the US Senate unveiled the draft text of the Infrastructure Investment and Jobs Act (Bill), a highly anticipated $1 trillion infrastructure package negotiated by the White House and a bipartisan group of...more
8/6/2021
/ Bitcoin ,
Brokers ,
Cash Transactions ,
Cryptocurrency ,
Digital Assets ,
Draft Guidance ,
Ether ,
Infrastructure ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Proposed Legislation ,
Reporting Requirements
On April 9, 2021, the Internal Revenue Service (IRS) released PLR 202114001 (PLR), which provides guidance on the deductibility of medical costs under Section 213 of the Internal Revenue Code (Code) relating to fertility...more
On April 9, 2021, the Internal Revenue Service (IRS) released Chief Counsel Advice memo 202114020 (Hard Fork CCA), which details the potential tax consequences for taxpayers who held Bitcoin prior to the August 1, 2017,...more
The Internal Revenue Service (IRS) ruled that a taxable real estate investment trust (REIT) subsidiary would not be considered to be operating or managing certain senior living and healthcare facilities located outside the...more
Recent guidance, including Revenue Procedure 2020-22, released on April 10, 2020, offers additional clarity to taxpayers affected by changes to the treatment of Qualified Improvement Property included in the CARES Act. The...more
The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more
1/29/2020
/ Capital Gains ,
Community Development ,
Economic Development ,
Estate Planning ,
Final Rules ,
FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Partnerships ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Exempt Entities ,
Tax Planning ,
Trusts ,
U.S. Treasury
The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more
5/3/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Community Development ,
Debt Financing ,
Economic Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Low Income Housing ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Safe Harbors ,
Tangible Property ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
U.S. Treasury