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ASKramer Law

Taxation of Foreign Currency Transactions Part V: Hedged Executory Contracts

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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

ASKramer Law

Taxation of Foreign Currency Transactions Part IV: Hedging & Section 1.988-5(a) Debt Hedges

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Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more

ASKramer Law

Taxation of Foreign Currency Transactions Part III: Section 988 Transactions Defined, Character & Source

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Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more

ASKramer Law

Taxation of Foreign Currency Transactions Part II: Gains, Losses, Personal Transactions, and Electing Out of Section 988

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Are all foreign currency gains taxable? No. Under a de minimis exemption individual taxpayers with foreign currency gains of $200 or less on a “personal transaction” do not need to report them....more

ASKramer Law

Taxation of Foreign Currency Transactions Part I: Definitions and Rules for Taxing Foreign Currencies

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Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more

Cadwalader, Wickersham & Taft LLP

Mini-Me Crypto Tax Legislation

Bipartisan crypto legislation was introduced by Senators Pat Toomey (R-PA) and Kyrsten Sinema (D-AZ) on July 26, 2022. If enacted, the Virtual Currency Tax Fairness Act would exclude from gross income gain on certain de...more

Cadwalader, Wickersham & Taft LLP

Is Staking a Taxable Service?

On February 3, the Proof of Stake Alliance (“POSA”), a cryptocurrency industry association, issued a press release regarding recent developments in a cryptocurrency tax case, in which the IRS approved the tax refund sought by...more

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

Foodman CPAs & Advisors

How Will Virtual Currency Be Taxed?

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Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

Dechert LLP

Cryptocurrency Stakeholders Should Prepare for Increased Tax Enforcement

Dechert LLP on

As we recently noted in our OnPoint dated October 20, 2021, the rise in interest from retail and institutional investors in the cryptocurrency market has attracted increased regulatory and enforcement attention in the past...more

Foodman CPAs & Advisors

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

Foodman CPAs & Advisors

The IRS Is Cracking Down On Cryptocurrency Tax Reporting

If you’ve engaged in cryptocurrency or other virtual currency transactions worth $20,000 in any one year between 2016 and 2020, the IRS wants to hear from you. The IRS believes thousands of taxpayers are not telling the...more

Foodman CPAs & Advisors

Did You Engage In Virtual Currency Transactions In 2020?

Taxpayers who engaged virtual currency   transactions in 2020 must answer a Yes or No Question on page 1 of Form 1040 or Form 1040-SR. The question is: “At any time during 2020, did you receive, sell, send, exchange or...more

Gray Reed

Taxpayer Guidelines for Cryptocurrency in 2021

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Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more

Kramer Levin Naftalis & Frankel LLP

Virtual Currency

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

Foodman CPAs & Advisors

Taxpayers, have you sold, received, exchanged or acquired Virtual Currency?

Foodman CPAs & Advisors on

During the month of October 2019, IRS issued Revenue Ruling 2019-24,  FAQ’s on Virtual Currency Transactions and a DRAFT Form of Schedule 1,  which, for the first time presents the question:  “At any time during 2019, did you...more

ArentFox Schiff

The End of Libor

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For a variety of reasons, as has been widely reported, LIBOR is to cease to be published by the end of 2021 and this expected elimination of the index upon which financing transactions are based raises serious tax and non-tax...more

Polsinelli

Stick a Fork in It? IRS Issues Updated Guidance on the Tax Treatment of Cryptocurrency Forks and Provides Answers to a List of...

Polsinelli on

Five years or so years ago, the Internal Revenue Service (“IRS”) provided its first, and until this week, only formal advice on the taxation of cryptocurrency transactions in Notice 2014-21. This guidance, while helpful in...more

Rosenberg Martin Greenberg LLP

The Crackdown on Cryptocurrency

We all read the headlines. Virtual currencies are a hot button topic. Even Facebook is developing their own virtual currency. It is easy to understand the attraction. The use of a virtual currency is anonymous. Account...more

Hogan Lovells

French legal and regulatory update - April 2019

Hogan Lovells on

The Paris office of Hogan Lovells is pleased to provide this English language edition of our monthly e-newsletter, which offers a legal and regulatory update covering France and Europe for April 2019. ...more

Foodman CPAs & Advisors

Tax Time and Virtual Currency

Virtual Currency (VC) investors continue to have accounting challenges at tax time. They are seeking to better understand and comply with their U.S. tax regulatory obligations when using VC. ...more

Foodman CPAs & Advisors

2018 is almost over and still no guidance from IRS on the treatment of Virtual Currency

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On September 19, 2018, the House Ways and Means Committee wrote a letter to the IRS urging the IRS to “issue updated guidance, providing additional clarity for Taxpayers seeking to better understand and comply with their tax...more

Foodman CPAs & Advisors

Lo que sabemos sobre el Cumplimiento Crypto y los impuestos federales de los EE. UU.

La última Notificación emitida por el IRS sobre Criptomoneda fue el Aviso 2014-21 publicado el 25 de Marzo del 2014 que brinda orientación en forma de respuestas a preguntas frecuentes (“Frequently Asked Questions”). ...more

Foodman CPAs & Advisors

What we know about Crypto Compliance and US Federal Taxes

The last Notice issued by the IRS on Cryptocurrency was Notice 2014-21 posted on March 25, 2014 providing guidance in the form of answers to frequently asked questions. ...more

Foodman CPAs & Advisors

Todos ganan al aceptar Monedas Virtuales como Medio de Pago

La aceptación de la moneda virtual (MV) como forma de pago de bienes y servicios está creciendo. Estados como Arizona y Georgia han presentado proyectos de ley que permitirían a los contribuyentes de esos Estados pagar sus...more

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