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Updated Alert: FinCEN Imposes New Reporting Requirements on LLCs and other Entities

As a reminder to our clients and friends of the firm, the beneficial ownership reporting deadline is soon approaching. Applicable entities that were formed or registered to do business in the U.S. prior to this year, have...more

US and Global Crypto Tax Update

Crypto tax policy continues to move forward, domestically and internationally. Domestically, the IRS seeks comments on the new Form 1099-DA. Internationally, the Organization for Economic Co-Operation and Development (“OECD”)...more

Final Tax Rules and Transitional Guidance for Broker Reporting

The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more

1% Stock Buy Back Tax; Little Relief for Issuers Under Final Tax Regulations

The U.S. Treasury finalized regulations (the “Regulations”), providing rules for public companies subject to the 1% excise tax on certain redemptions of their publicly traded stock (the “Stock Repurchase Excise Tax”). The...more

New FATCA Agreement with Switzerland

The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more

IRS Proposes Regulations Regarding Tax Treatment of Certain Basket Option Contracts and Basket Contracts

Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...more

New IRS Tax Form for Digital Asset Broker Reporting

The IRS released a draft of a new tax form, Form 1099-DA, that brokers will use to report proceeds from certain digital asset transactions. The draft Form 1099-DA can be found on the IRS website and below. The effective date...more

Greenbook Tax Proposals

Tax reform, like spring, is in the air. The Biden Administration recently released its fiscal year 2025 revenue proposals, known as the annual “Greenbook.” The Greenbook’s 250+ pages of tax reforms include six potential...more

Crypto Tax Evasion is Just…Tax Evasion

Tax evasion is as old as tax collection, so it is no surprise that there is tax evasion related to crypto. In a recent case, United States v. Frank Ahlgren III, Federal prosecutors allege that between 2017 and 2019, the...more

IRS Says Digital Assets Are Not (Yet) Subject to Cash Reporting Obligations

The Internal Revenue Service (“IRS”) issued an announcement that it is delaying implementation of reporting obligations for businesses that accept large amounts of digital assets. This SKrypto Blog Post summarizes cash and...more

For Fund Managers, Tax Court Ruling Sets Limited Partners Back “As Such”

Memorandum to our Investment Management Clients and Friends - The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more

FinCEN Imposes New Reporting Requirements on LLCs and Other Entities

The Corporate Transparency Act (the “CTA”), a set of new regulations being implemented by the Financial Crimes Enforcement Network (“FinCEN”), requires entities newly formed or registered to do business in the United States...more

Proposed Tax Relief and Jobs Package

August 22, 2023 Earlier this summer, the House Committee on Ways and Means introduced a tax relief package (the “Proposals”), which establishes a framework for potential tax changes. The Proposals are not expected to be...more

IRS Raises the Stakes on Staking

The IRS published guidance on the federal income tax treatment of staking income in Revenue Ruling 2023-14.  Consistent with its prior ruling on hard forks, the IRS maintains that taxpayers realize taxable income when he or...more

NFT Means Never Forget Taxes: Redux

The Internal Revenue Service released Notice 2023-27 (the “Notice”), providing guidance on the federal tax treatment of nonfungible tokens (“NFTs”). In a prior SKRYPTO blogpost, we noted that investors selling NFTs could be...more

New York City Implements Pass-Through Entity Tax for 2022

This Memorandum discusses the New York City pass-through entity tax (“PTET”) election. Partnerships and S corporations with New York City resident partners, members or shareholders may elect into this tax. Once elected, New...more

July 2022 U.S. Federal Income Tax Updates

This Memorandum highlights several important U.S. federal income tax developments in the summer of 2022, including: (i) the Supreme Court agreeing to hear an FBAR penalty case, (ii) the Internal Revenue Service (“IRS”)...more

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