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Expert Testimony May Be Limited if ‘Confidential’ Information Is Withheld Under Section 6103

Expert witnesses can be critical to defending a tax position—but what happens when an expert must maintain confidentiality over information that is important to their analysis? Preserving this confidentiality while ensuring a...more

Key Takeaways: US-Canada Transfer Pricing & Tax Controversies: What’s New, What’s Not, and How to Prepare for Both

The global tax enforcement landscape is progressing rapidly, driven by regulatory changes, increasing cross-border collaboration, and shifts in funding for key tax authorities. Businesses operating in multiple jurisdictions...more

New IRS Guidance Provides a Spot of Certainty Amid Digital Asset Limbo

Per recent transitional guidance, the IRS will not require taxpayers to report transactions involving receipt of digital assets under Section 6050I....more

IRS Releases Proposed Digital Asset Regulations

The Internal Revenue Service (IRS) recently released proposed regulations regarding broker reporting for digital assets, including expansions of and additions to certain definitions, rules, and requirements. The IRS seeks...more

Digital Asset Brokers: Proceed with Caution

The IRS has effectively delayed the implementation of the new digital asset broker rules under Internal Revenue Code Sections 6045 and 6045A. The US Treasury Department (Treasury) and Internal Revenue Service (IRS) recently...more

Bipartisan Proposal Attempts to Provide Solutions for Comprehensive Regulation of Digital Assets

On June 7, 2022, Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) introduced the Responsible Financial Innovation Act (RFIA), a bipartisan effort to develop and provide greater regulatory clarity to the eclectic...more

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