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Internal Revenue Service Internal Revenue Code (IRC) Financial Transactions

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Allen Barron, Inc.

Will You Recognize the Form 1099-K When You Receive it This Year?

Allen Barron, Inc. on

Will you recognize the Form 1099-K when you receive it from one or more third-party marketplace providers this year?  A few years ago, the IRS implemented new reporting requirements for many popular peer-to-peer payment apps...more

ASKramer Law

Taxation of Foreign Currency Transactions Part V: Hedged Executory Contracts

ASKramer Law on

What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more

ASKramer Law

Taxation of Foreign Currency Transactions Part IV: Hedging & Section 1.988-5(a) Debt Hedges

ASKramer Law on

Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more

ASKramer Law

Taxation of Foreign Currency Transactions Part III: Section 988 Transactions Defined, Character & Source

ASKramer Law on

Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more

Rivkin Radler LLP

Partnership Transactions Lacking Economic Substance or Business Purpose: Investor Beware

Rivkin Radler LLP on

Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than...more

Littler

IRS Updates FAQs on 1099-Ks Used for Gig Workers and Others

Littler on

The IRS recently updated its guidance for completing Form 1099-K, used primarily by “gig” companies providing compensation using payment apps or online marketplaces and for individuals selling goods on online marketplaces...more

Cadwalader, Wickersham & Taft LLP

ABA Tax Section Comments on Proposed Crypto Broker Reporting Regulations

On December 20th, 2023, the American Bar Association Tax Section published detailed comments and recommendations (the “ABA Comments”) on the proposed crypto broker reporting regulations.  As discussed here, the New York State...more

Cadwalader, Wickersham & Taft LLP

Treasury Cries “Uncle” to Crypto Industry: Crypto Reporting Delayed

On January 16th, the IRS published Announcement 2024-4 (the “Announcement”), postponing certain reporting requirements for large crypto transactions which were set to go into effect for the 2024 tax year.  Persons engaged in...more

Foodman CPAs & Advisors

¡Libros Y Registros Adecuados Pasados Por Alto A Menudo!

La Sección 6001 del Código de Rentas Internas requiere que los contribuyentes mantengan libros y registros adecuados y “que toda persona responsable de cualquier impuesto requerido por el Código, o de su recaudación, debe...more

Foodman CPAs & Advisors

Adequate Books And Records Often Overlooked!

Internal Revenue Code Section 6001 requires Taxpayers to maintain adequate books and records and “that that every person liable for any tax imposed by the Code, or for the collection thereof, must keep such records, render...more

Nelson Mullins Riley & Scarborough LLP

Nelson Mullins Tax Report – Proposed Regulations on Information Reporting for Digital Asset Sales and Exchanges

On August 29, 2023, the Internal Revenue Service (IRS) issued new proposed regulations regarding reporting obligations for parties engaged in certain digital transactions.  The proposed regulations address the reporting...more

McDermott Will & Emery

What is the Significance of Virtual Currency Not Being Taxed as Currency?

McDermott Will & Emery on

Virtual currencies are not currently accepted as the legal tender or “fiat” currency of any country. In the United States, the IRS has stated its view that convertible virtual currency is property, subject to the general tax...more

Foodman CPAs & Advisors

Wondering About The Tax Treatment Of A Cryptocurrency Hard Fork And Airdrop?

Foodman CPAs & Advisors on

On 10/9/19, IRS issued Rev. Rul. 2019-24 addressing the issues of a Taxpayer having gross income under § 61 of the Internal Revenue Code as a result of a hard fork of a cryptocurrency that the Taxpayer owns if the Taxpayer...more

Holland & Knight LLP

Virtual Currency: The Taxman is Coming

Holland & Knight LLP on

Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more

Jones Day

Blockchain and Tax: Navigating Uncertainty

Jones Day on

Virtual currencies (often called cryptocurrencies) such as bitcoin are perhaps blockchain's best-known application. As these and other blockchain-based digital assets become more common, and attract more regulatory and...more

Foodman CPAs & Advisors

Tax Time and Virtual Currency

Virtual Currency (VC) investors continue to have accounting challenges at tax time. They are seeking to better understand and comply with their U.S. tax regulatory obligations when using VC. ...more

Foodman CPAs & Advisors

Los titulares de Moneda Virtual (MV) NECESITAN MANTENER REGISTROS

Foodman CPAs & Advisors on

La Sección 6001 del Código de Rentas Internas requiere que los Contribuyentes mantengan libros y registros adecuados. Mantener libros adecuados y buenos registros de la MV ayudará al Contribuyente a...more

Foodman CPAs & Advisors

Virtual Currency (VC) Holders NEED to KEEP RECORDS

Foodman CPAs & Advisors on

Internal Revenue Code Section 6001 requires Taxpayers to maintain adequate books and records. Keeping adequate VC books and good records will assist a Taxpayer to...more

Foodman CPAs & Advisors

Did you know that IRS is running 35 Campaigns?

In January 2017, the IRS Large Business and International Division initially announced the launch of a “compliance campaign process” in which IRS identifies compliance issues that present risk and require a response in the...more

Foodman CPAs & Advisors

Swapping Virtual Currencies will trigger tax obligations under the Tax Cuts and Jobs Act

There are investors that have an interest in “exchanging or swapping” Virtual Currency (VC). Prior to the passage of the Tax Cut and Jobs Act (TCJA), VC investors could take the position that if they “exchanged or swapped”...more

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