In a US District Court complaint filed May 26, 2021, a married couple is seeking a refund of taxes they paid on cryptocurrency tokens the husband created, asserting that current law does not permit the treatment of created...more
6/23/2021
/ Asset Tokens ,
Blockchain ,
Coinbase ,
Cryptocurrency ,
Data Mining ,
Distributed Ledger Technology (DLT) ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Personal Property ,
Popular ,
Reporting Requirements ,
Tax Refunds ,
Token Sales
On May 24, 2021, Sen. Warren introduced Senate Bill 1788, the “Restoring the IRS Act” (the Proposed Legislation). The Proposed Legislation generally (1) imposes new information reporting obligations on financial institutions...more
6/1/2021
/ American Rescue Plan Act of 2021 ,
Biden Administration ,
Elizabeth Warren ,
Enforcement ,
False Claims Act (FCA) ,
FATCA ,
Financial Institutions ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Legislation ,
Reporting Requirements ,
Tax Avoidance ,
Tax Penalties
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on:
..Transfer pricing for “captive” services...more
4/29/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
FATCA ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
OECD ,
Offshore Banks ,
OVDP ,
Related Parties ,
Transfer Pricing
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
3/25/2019
/ Controlled Foreign Corporations ,
Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Passive Foreign Investment Company ,
Public Comment ,
Registered Investment Companies (RICs) ,
Rulemaking Process ,
Securities ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
On October 16, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-54, which addresses the treatment of a new mortgage-backed security under the diversification rules of IRC § 817(h). This new security, called a...more
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more
On July 8, the Internal Revenue Service (IRS) issued two notices (Notice 2015-47, 2015-30 IRB 1, and Notice 2015-48, 2015-30 IRB 1) targeting the use of Basket Option Contracts and Basket Contracts as tax avoidance...more
On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more