The United States Internal Revenue Service (“IRS”) issued Announcement 2024-19 titled: Federal Tax Treatment of Amounts Paid Toward the Purchase of Energy Efficient Property and Improvements Under Department of Energy...more
Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more
Businesses often manage their price risks by hedging those risks with financial derivative contracts. Because businesses generate ordinary income and loss on their normal business activities, they want to be sure their...more
Crypto industry groups had hoped to use the tax refund case of Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.) as the vehicle to prove that staking rewards received by a crypto validator only trigger gain upon the...more
Under current FinCEN regulations, a foreign account holding virtual currency is not reportable on the FBAR. However, FinCEN in its FinCEN Notice 2020-2, proposes amending reports of foreign financial accounts (FBAR)...more
On Monday, June 8, 2020, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released Proposed Regulations addressing the tax treatment of amounts paid for two unique types of medical arrangements –...more
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
On May 30, 2018, the AICPA (American Institute of Certified Public Accountants) wrote a letter to the IRS to obtain further definition and clarity regarding Virtual Currency (VC) FATCA and FBAR reporting requirements....more
On 5/30/18, the American Institute of CPAs (AICPA) sent a letter (https://www.aicpa.org/content/dam/aicpa/advocacy/tax/downloadabledocuments/20180530-aicpa-comment-letter-on-notice-2014-21-virtual-currency.pdf) to the IRS...more
The IRS has released Announcement 2017-11 to provide relief to taxpayers from requirements for loans and hardship distributions for participants of qualified retirement plans who have been adversely affected by Hurricane...more
On January 19, 2017, the Internal Revenue Service (IRS) issued Rev. Proc. 2017-19, 2016-6 I.R.B. (the Rev. Proc.), providing a safe harbor under which it will not challenge the tax treatment of an Energy Savings Performance...more
In March, the Internal Revenue Service published an IRS Large Business & International (LB&I) Directive (the Directive), which updates an earlier directive to field agents addressing the examination of capitalization and...more
The California Fourth District Court of Appeal adopted the principle that it is inherently unreasonable for any person to rely on a prediction of future IRS enactment, enforcement, or non-enforcement of the law by someone...more