PLI's inSecurities Podcast - Opening the Securities Enforcement Answer Book
PLI's inSecurities Podcast: A View From the Inside
PLI's inSecurities Podcast: Whistling the Same Tune: Building an Effective Whistleblower Program
PLI's inSecurities Podcast - Commissioner Jaime Lizárraga’s Core Values
The Justice Insiders Podcast: Feds Danske to a New Tune
Crypto, Best Ex, Gatekeepers, Enforcement: The Biggest Stories From 2022
CYBER THURSDAY!
Crypto and the SEC - The Crypto Exchange Podcast
Coffee & Regs - Digital Assets: Trading & Compliance for Cryptocurrency
The Insider Trading Cartoon Series, Vol. V — Misappropriation Theory
CorpCast Episode 1: Sections, 204, 205 and In re Numoda
What is Bitcoin 2.0?
Insider Trading News - Ralph Siciliano discusses US v. Newman
Types of Crowdfunding
Keith Ross on HFT, Reg NMS and Dark Pools
Open for Business: SEF Competition Heating Up in the New Market Structure
Open for Business: SEFs Navigate the New Regulatory Environment
The last week of June saw a flurry of legal developments in quick succession. The SEC sued Consensys, the developers of the largest self-custodial digital wallet (MetaMask). The IRS released its digital asset tax rules. The...more
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
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 13, 2024 – May 17, 2024....more
The Tax Court’s decision in YA Global Investments LP v. Commissioner in November sends a warning to the offshore banking, finance and equity investment industries: an offshore entity is engaged in U.S. trade or business when...more
Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their...more
El 11/08/23, el IRS anunció que, en las circunstancias adecuadas, los contribuyentes internacionales podrán utilizar una nueva herramienta totalmente electrónica para presentar solicitudes de alivio de multas del IRS para...more
On 8/11/23, the IRS announced that under the right circumstances, international taxpayers will be able to use a new, fully electronic tool to submit penalty IRS relief requests for a few late-filed forms: a fax...more
In response to a provision in the 2021 Infrastructure Investment and Jobs Act, the Department of the Treasury and the Internal Revenue Service (IRS) have issued proposed regulations that would impose new tax reporting...more
What Is It? Where one stands on an issue of tax law may depend upon context and perspective, including the facts and circumstances one finds relevant, and whom one is counseling or representing. Tax advisers often find...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...more
The pandemic’s impact may be subsiding, but businesses are encountering new challenges across the globe, including the potential for an economic retrenchment, rising interest rates, shifting regulatory and litigation...more
On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the "Inflation Reduction Act" (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more
On March 28, 2022, the US Department of the Treasury released the Fiscal Year (FY) 2023 Revenue Proposals and Green Book, which describes the tax proposals in the Biden administration’s FY 2023 budget (2023 Budget Proposal)....more
Today’s supply chains are frequently paper-based operations subject to human error and delay. Therefore, some companies are beginning to invest in digital infrastructure, including blockchain tools, to strengthen supply...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 21, 2020 – September 25, 2020... September 21, 2020: The IRS released Announcement...more
The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more
Simple Agreements for Future Tokens pose difficult and controversial legal questions under U.S. securities, commodities and tax laws. SAFT holders face significant difficulties in securing liquidity, and regulatory issues...more
Traders in virtual currency seeking to deduct trading losses and avoid application of the capital loss limitations would want to elect into the special tax rules found at I.R.C. § 475(f). However, such taxpayers should...more
Under the wash sales rule, taxpayers cannot deduct a loss on the sale of stock or securities if the taxpayer purchases the same or substantially similar assets a short time before or after the sale that triggered the loss....more
Recently-finalized, regulations provide that, in determining whether a corporation is a regulated investment company (RIC), amounts the corporation is required to include in income as a result of its investment in foreign...more
On March 18, 2019, the U.S. Department of the Treasury and the Internal Revenue Service issued final tax regulations for registered investment funds that are taxed as regulated investment companies (“RICs”) and that invest in...more
On March 19, 2019, the Internal Revenue Service (IRS) and Treasury Department (Treasury) issued final regulations (T.D. 9851) (Final Regulations) under section 851 addressing the income test applicable to regulated investment...more
Virtual Currency (VC) investors are currently investing without clarity regarding which Government Agency(s) has the final word with respect to the treatment of VC. US Agencies: IRS, FinCEN, SEC and CFTC – have expressed...more
The Department of Justice and the Securities and Exchange Commission opposed a motion to dismiss filed by a defendant named in a criminal indictment, charging him with offering and selling two types of digital tokens issued...more
On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more