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ASKramer Law

Business Taxation of Hedging Transactions Part V: Consolidated Groups

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Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...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

Polsinelli

IRS Advises that Virtual Currency Received in Exchange for Microtasking is Subject to Ordinary Income Tax and Self-Employment Tax

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As discussed in previous blog entries , the IRS has been engaged in an ongoing campaign intended to address noncompliance related to the use of crypto currencies, including a virtual currency compliance campaign spearheaded...more

Foster Garvey PC

The IRS Provides Some Good News to Oregonians During a Time When Positive News Is Rare – News Releases OR-2020-23 and IR-2020-215

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When we thought times were bad enough with the COVID-19 pandemic and widespread social unrest in our country, the West Coast, including the Pacific Northwest, was struck with unprecedented wildfires and massive windstorms,...more

Foodman CPAs & Advisors

Treasury and IRS are Aiming to Provide Greater Clarity on International Tax Reporting

On July 14, 2020, the US Treasury Department and the IRS released a proposed redesigned partnership form for tax year 2021 (filing season 2022). The two proposed forms SCHEDULE K-2 (Form 1065) and Schedule K-3 (Form 1065) are...more

Foodman CPAs & Advisors

Willfulness and IRS Foreign Account Reporting Requirements

The IRS Mission Statement states that: “the taxpayer’s role is to understand and meet his or her tax obligations”.   Taxpayers fill out their own returns under a “self-assessment voluntary reporting system” because the...more

Foodman CPAs & Advisors

Did you know that IRS reinstated the “ASFR” program in 2019?

Under Internal Revenue Code, Section 6620, if a Taxpayer does not timely file a U.S. tax return, the IRS is authorized to prepare and file a U.S. tax return for that Taxpayer based on the knowledge that it has on hand. ...more

Bowditch & Dewey

IRS Discusses New IRS Return Examination Campaigns

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In remarks at the NYU Tax Controversy Forum in June, the IRS discussed two new IRS return examination campaigns. Ms. Tamera Ripperda, the commissioner of the Tax Exempt and Government Entities (TEGE) Division who previously...more

McDermott Will & Emery

Weekly IRS Roundup January 6 – January 10, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6 – January 10, 2020. January 6, 2020: The IRS issued a News Release confirming that the...more

McDermott Will & Emery

Weekly IRS Roundup December 30, 2019 – January 3, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 30, 2019 – January 3, 2020. December 30, 2019: The IRS issued a news release announcing...more

McDermott Will & Emery

Weekly IRS Roundup December 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

McDermott Will & Emery

Weekly IRS Roundup December 2 – 6, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 2 – 6, 2019. December 2, 2019: The IRS issued final regulations providing guidance...more

Holland & Knight LLP

Virtual Currency: The Taxman is Coming

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Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more

Foodman CPAs & Advisors

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

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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

Polsinelli

IRS Issues Sends Letters to Over 10,000 Taxpayers with Cryptocurrency Transactions Without Providing Anticipated Guidance

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On July 26, 2019, the IRS announced that it was in the process of sending letters to over 10,000 taxpayers with a history of cryptocurrency transactions by the end of August, noting that the letters were sent to taxpayers...more

Snell & Wilmer

Taxpayer Cybersecurity – Step 4: Recognize Identity Theft

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The Security Summit, consisting of the Internal Revenue Service (“IRS”), state tax agencies, and private-sector tax industry officials, is encouraging tax professionals during the 2019 summer season to take some time to...more

Foster Garvey PC

Oregon’s New Corporate Activity Tax

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We are taking a break from our multi-post coverage of Opportunity Zones to address a recent, significant piece of Oregon tax legislation. On May 16, 2019, Governor Kate Brown signed into law legislation imposing a new...more

Foodman CPAs & Advisors

The “J5” is on to Cryptocurrencies

The Organisation for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. The result of this “call to action” was the establishment of an...more

Orrick, Herrington & Sutcliffe LLP

Annual Reporting Requirements for Incentive Stock Options and Employee Stock Purchase Plans (UPDATED)

Requirement to Report For (1) any exercise of an incentive stock option (ISO) during 2017 or (2) transfer during 2017 of a share previously purchased pursuant to a tax-qualified employee stock purchase plan (ESPP), the...more

Foodman CPAs & Advisors

Many are now looking for IRS Guidance on Virtual Currency

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Due to its unprecedented level of value appreciation, Bitcoin investors, consumers and businesses are looking for IRS Guidance. IRS recognizes that “virtual currency” may be used to pay for goods or services, or be held for...more

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