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This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more
On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more
In recent months, the increased focus on cryptocurrency regulation and enforcement at both the federal and state levels demonstrates the digital currency’s place as an established component of the financial landscape. At the...more
The Internal Revenue Service (IRS) has scored another significant victory in its rapidly increasing virtual currency tax enforcement efforts. On May 5, 2021, the US District Court for the Northern District of California...more
CFTC Releases Digital Asset Primer - On December 17, 2020, the CFTC announced a 36-slide Digital Assets Primer. The Digital Assets Primer seeks to build on a prior 2017 release that focused on virtual currencies. This...more
On Oct. 9, 2019, the Internal Revenue Service (the “Service”) issued Revenue Ruling 2019-24 concerning the tax consequences of virtual currency hard forks, as well as FAQs on the taxation of virtual currency generally. This...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
The Organisation for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. The result of this “call to action” was the establishment of an...more
The Federal Energy Regulatory Commission (FERC) announced on July 19, 2018, that it is directing the North American Electric Reliability Corporation (NERC) “to develop and submit modifications to the NERC Reliability...more
El Jefe de Investigación Criminal del IRS, Don Fort, declaró recientemente: "Es posible utilizar Bitcoin y otras Criptomonedas de la misma manera que las cuentas bancarias extranjeras para facilitar la evasión de impuestos"....more
Argentina - Virtual currencies are not legal tender under the country’s National Constitution, which designates the Central Bank as the only authority that may issue legal tender. Although not specifically regulated,...more
An Overview of Proposed Regulation AT - Orrick attorneys authored an overview of Regulation Automated Trading (known as "Regulation AT") proposed by the Commodity Futures Trading Commission ("CFTC") in the May/June 2016...more