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New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

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

Cryptocurrency Tax Update: Impact of New IRS Guidance and Proposed U.S. Tax Rate Increase

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

JONES DAY TALKSĀ®: Hard Forks and Airdrops: The IRS Issues Cryptocurrency Tax Guidance  [Audio]

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

U.S. Treasury Releases Proposed FIRPTA Regulations

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

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