In a recent Chief Council Advisory, the IRS found that certain cryptocurrencies did not qualify as like-kind exchanges under section 1031 prior to the Tax Cuts & Jobs Act of 2017. The IRS’s ruling, while limited to coin...more
President Biden has proposed major changes to the Federal tax laws, some of which are sought to be effective earlier in 2021 (i.e., we are already operating under these changes, if they later become adopted), as compared to...more
Just days before we all sat down to eat our Thanksgiving dinners, the Treasury Department gave us something else to digest: final like-kind exchange regulations. These regulations define “real property” for purposes of Code...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 23, 2020 – November 27, 2020... November 23, 2020: The IRS released TD 9935, providing...more
IRS Grants Automatic Extension of Federal Tax Returns - Between March 17 and April 9, 2020, the U.S. Department of the Treasury and the Internal Revenue Service issued a series of notices automatically extending to July 15...more
NOTICE 2020-23 - On April 9, 2020, the U.S. Secretary of the Treasury issued Notice 2020-23. It greatly expands the tax compliance relief previously granted to taxpayers in response to the COVID-19 pandemic....more
Due to the ongoing COVID-19 pandemic, the IRS has granted taxpayers an automatic extension for the deadlines imposed by section 1031 of the Tax Code for like-kind exchanges. In IRS Notice 2020-23, released on April 9, 2020,...more
On January 28, 2020, the California Office of Tax Appeals (OTA) denied the California Franchise Tax Board’s (FTB) request to rehear In the Matter of the Appeal of Sharon Mitchell (OTA Case No. 18011715). This decision may...more
Within the past year, the IRS has not changed its position on the way they are treating the taxation and reporting of digital token transactions. This alert serves as an update to last year’s rundown of cryptocurrency...more
On April 11, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts (including contracts for...more
New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more
In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more