On August 29, 2023, the Internal Revenue Service (IRS) published new proposed regulations on tax reporting requirements for cryptocurrency brokers. The proposed regulations build on efforts to expand IRS regulation over...more
On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which concludes that the fair market value of staking rewards received by a cash-method taxpayer is includible in the taxpayer’s gross...more
On April 21, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice memorandum (ILM 202316008), concluding that a protocol upgrade to the consensus mechanism of a cryptocurrency blockchain that did not...more
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
On January 13, 2023, the Internal Revenue Service (IRS) released a memorandum (CCA 202302012) concluding that a qualified appraisal is required when a taxpayer claims a charitable contribution deduction exceeding $5,000 for...more
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 June 7, 2022, Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) introduced the highly anticipated Responsible Financial Innovation Act (the bill), which sets out to create the first complete regulatory and...more
7/15/2022
/ Brokers ,
CFTC ,
Digital Assets ,
Disclosure Requirements ,
Investment ,
IRS ,
Lending ,
Loan Agreements ,
New Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Retirement Account Loans ,
Safe Harbors ,
Securities and Exchange Commission (SEC) ,
Taxation
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
Stakers—taxpayers involved in proof of stake (PoS) validation of blockchain transactions—continue to operate in uncharted tax waters. PoS blockchains represent over half of the $1.68 trillion cryptocurrency market...more
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 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
Loans under the Payroll Protection Program (PPP) are eligible for forgiveness depending upon whether and when the loan proceeds are used for qualified business expenses. One of the benefits of this program is that there is no...more
Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more
12/18/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Business Judgment Rule ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Revenue Procedures ,
Subpart F ,
Treasury Regulations
On August 21, 2018, the IRS issued guidance regarding recent statutory changes made to Section 162(m) of the Internal Revenue Code. Overall, Notice 2018-68 strictly interprets the Section 162(m) grandfathering rule under the...more
Significant Changes in US Tax System Likely -
In the short time since the surprising election of Donald J. Trump as the 45th president of the United States, much already has been written about the likelihood and likely...more
12/13/2016
/ Corporate Taxes ,
Debt-Equity ,
Deferred Compensation ,
International Tax Issues ,
IRS ,
REIT ,
SALT ,
Section 409A ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK
In This Issue:
- Distinguishing Between Captive Insurance and Related Party Derivatives: Chief Counsel Advice Memorandum 201511021
- Achieving Tax-Free ‘Rollover’ Treatment for Certain Shareholders in Acquisition of...more
Section 162(m) generally limits to $1 million the amount that a public company can annually deduct with respect to remuneration paid to certain covered employees. This deduction limitation, however, does not apply to...more