Businesses often manage their price risks by hedging those risks with financial derivative contracts. Because businesses generate ordinary income and loss on their normal business activities, they want to be sure their...more
It is a common practice for businesses to manage their business price risks by entering into derivative contracts. Because their business activities generate ordinary income and loss, they want to obtain ordinary tax...more
Crypto industry groups had hoped to use the tax refund case of Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.) as the vehicle to prove that staking rewards received by a crypto validator only trigger gain upon the...more
The 2021 Italian Budget Law aligns the tax treatment applicable to EU investment funds with the tax treatment applicable to Italian investment funds....more
There are a number of well-known stories of equity compensation, often focusing on the tax outcomes for awards where fortunate optionees did everything right. Some of these stories are actual outcomes, such as when ISOs that...more
Five years or so years ago, the Internal Revenue Service (“IRS”) provided its first, and until this week, only formal advice on the taxation of cryptocurrency transactions in Notice 2014-21. This guidance, while helpful in...more