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
12/3/2019
/ Bitcoin ,
Blockchain ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Filing Requirements ,
Financial Transactions ,
Income Taxes ,
Investment ,
IRS ,
New Guidance ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Virtual Currency
On Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more
11/18/2019
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bifurcation ,
Controlling Stockholders ,
Debt ,
Debt-Equity ,
Debtor-Creditor ,
Distribution Rules ,
Equity ,
Identity of Interest ,
IRS ,
New Regulations ,
Regulatory Standards ,
Rulemaking Process ,
Section 385 ,
Stocks ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
On Aug. 14, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published proposed regulations (the Proposed Regulations) regarding the classification of “cloud transactions” for...more
10/7/2019
/ Cloud Computing ,
Data Transfers ,
Digital Assets ,
Digital Platforms ,
Digital Services ,
Factoring Transactions ,
IaaS ,
IRS ,
PaaS ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process ,
SaaS ,
Software ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
The meteoric rise of cryptocurrencies has created a stir in the financial and investment communities. The Securities and Exchange Commission, along with other regulatory bodies, is taking an active role in policing and...more
In a recent decision, Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, the U.S. Tax Court declined to follow Revenue Ruling 91-32, and held that gain on the sale of an interest in an operating...more