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US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
AGG Talks: Cross-Border Business - Episode 12: A General Counsel’s Map for International Business Expansion - Part 2
AGG Talks: Cross-Border Business - Episode 12: A General Counsel’s Map for International Business Expansion - Part 1
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The Trump administration continues its efforts to relax digital asset regulation, including most recently by exempting decentralized finance ("DeFi") apps and wallets from tax reporting and through Securities and Exchange...more
In light of the approaching April 15 tax filing deadline, this week’s update highlights recent developments in U.S. federal tax policy that may impact crypto firms and crypto holders....more
The crypto tax space saw significant developments in 2024. As 2025 ushers in new regulatory shifts (as our colleagues discussed here), tax changes may be on the horizon. In anticipation, this review revisits crypto tax...more
On June 28, 2024, the Treasury and the IRS released final regulations on reporting requirements for brokers of digital assets (the “Final Regulations”) and provided transitional relief, including Notice 2024-56, Notice...more
In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more
The IRS released a draft of Form 1099-DA “Digital Asset Proceeds from Broker Transactions” in April which will require anyone defined as a “broker” to report certain information related to the sale of digital assets. The new...more
Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued last year, the IRS recently increased its oversight of cryptocurrency...more
How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more
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
On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more
The Crypto-Asset Reporting Framework (“CARF”), is the OECD’s flagship tax transparency standard to help combat criminal activity using crypto-assets to evade taxation. The key aspects of the CARF were covered in the article...more
On June 30, 2023 the District Court in the Northern District of California granted a petition to enforce the cryptocurrency exchange Kraken to release customer information. Specifically, Kraken was ordered to produce the...more
Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry. By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more
The Internal Revenue Service (“IRS”) recently issued guidance in Revenue Ruling 2023-14, holding that taxpayers who stake their cryptocurrency and receive additional units of cryptocurrency as rewards when validation occurs...more
Since 2019, Form 1040 has included a general question regarding the taxpayer’s cryptocurrency activity. Over the years, the IRS has modified the scope of its cryptocurrency inquiry. On the 2021 Form 1040, this question read:...more
What is Tokenization? Tokenization is the process of converting an asset into a token on the blockchain. It operates by dividing—or fractionalizing—the ownership of an asset (whether the asset is a piece of real estate or...more
IRS Commissioner Charles Rettig, testifying before Congress in April 2021, estimated the gap between taxes owed and taxes collected in the United States to be close to $1 trillion....more
With the emergence of digital assets, the question has arisen whether digital assets held in “wallets” in foreign exchanges need to be reported on Internal Revenue Service (IRS) Form 8938, Statement of Specified Foreign...more
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