Taxpayers can take a tax deduction with respect to “theft” losses that result from an illegal “taking of property” done with criminal intent. Among various other types of criminal activities, fraud is treated as theft under...more
A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax related factors that need to be considered, this is often (at least in...more
Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more
When taxpayers sell digital assets at a loss, their tax loss is quite straightforward. Their loss equals the amount that their tax basis exceeds the amount they received for the sale. This is not the only way for a taxpayer...more
The IRS wash-sale rule does not currently apply to cryptocurrency because the IRS considers virtual currencies to be property rather than securities. In general, a taxpayer who exchanges cryptocurrency for goods, services or...more
Dado que estamos en pleno apogeo de la temporada de impuestos, muchos contribuyentes están explorando la posibilidad de reclamar una deducción de impuestos cripto sobre sus activos cripto “devaluados”. Los contribuyentes...more
Who may be interested: Registered Investment Advisers, Robo-advisers, Compliance Staff. Quick Take: The SEC settled charges against a registered adviser for misstating and omitting material information about the...more
On January 13, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice Memorandum (CCA 202302011) concluding that taxpayers cannot claim a deduction for cryptocurrency losses that have, absent a sale or other...more
Some investors who experienced rapid declines in the value of their cryptocurrencies during 2022 may be attempting to claim 2022 tax losses. According to the IRS’s Office of Chief Counsel, some of these investors may be out...more
Debacle- Understanding the etymology of a word often enables us to better understand or appreciate its use in contemporary speech. For example, the word “crypto” is derived from the Greek word “krypto,” which describes...more
Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more
Reportedly, there are over a million creditors in the bankruptcy of the cryptocurrency exchange FTX and its affiliated entities. A substantial number of these FTX creditors may include U.S. retail customers who held and...more
What a Week- There is no denying that last week’s political events were historic; one can only hope they were aberrational. The week began with the Sunday New York Times publishing a story in which it claimed to have...more
Under the wash sales rule, taxpayers cannot deduct a loss on the sale of stock or securities if the taxpayer purchases the same or substantially similar assets a short time before or after the sale that triggered the loss....more
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more
This article is produced by our London Tax team, which is part of our global Tax practice. Our series, "Understanding Tax", explores commercially relevant and recent changes to the UK's tax code. The true value of UK tax...more