On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more
The IRS recently clarified its position on the U.S. income tax treatment of a hard fork. A hard fork occurs when protocols on a blockchain change, causing a "fork" or splintering of the existing blockchain into two distinct...more
The IRS's first guidance on the taxation of cryptocurrency in five years provides some new insights, but also leaves several issues unresolved.
Jones Day partner Lori Hellkamp discusses Revenue Ruling 2019-24, with...more
New IRS guidance issued on qualified foreign pension fund exception.
On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more
6/13/2019
/ Anti-Abuse Rule ,
FATCA ,
FIRPTA ,
Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
Pension Funds ,
Proposed Regulation