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The IRS has not issued any clear guidance on the taxation of staking rewards. In 2014, the IRS issued Notice 2014-21, which provides that cryptocurrency is treated as property for
Continue Reading A Recent Court Case Leaves Many Speculating on the Taxation of Staking Rewards
The U.S. Senate passed its infrastructure bill (the “Bill”) that includes additional cryptocurrency reporting requirements, which are expected to generate $28 billion in revenue. The Bill currently does not provide
Continue Reading UPDATED: Infrastructure Bill Contains New Cryptocurrency Reporting Requirements
On July 28, 2021, the IRS secured two victories in court. The first win allows the IRS to impose an additional 35% penalty on an individual as the sole owner
Continue Reading IRS Secures Two Court Victories Involving Foreign Financial Activity
On May 20, 2021, the Treasury Department released a report that proposes new reporting requirements for transactions, including cryptocurrency transactions. Under the proposed plan, financial institutions, payment settlement entities, and
Continue Reading The Biden Administration Proposes New Cryptocurrency Reporting Rules
Recent John Doe summonses show the IRS is expanding its use of those summonses to aggressively investigate potential tax evasion. Within the past week, the IRS has received authorization to
Continue Reading The IRS Continues Aggressive Use of John Doe Summonses to Investigate Tax Evasion Related to Use of Cryptocurrency, Offshore Service Providers
On April 19, 2021, the IRS announced the establishment of a new Office of Promoter Investigations (OPI). The creation of OPI demonstrates the IRS’s commitment to pursuing promoters and combating
Continue Reading IRS Establishes Office of Promoter Investigations with Emphasis on Conservation Easements and Micro-captive Insurance Arrangements
Taxpayers that have engaged in cryptocurrency transactions should be aware that the Internal Revenue Service is seeking customer records from cryptocurrency exchanges. The Department of Justice recently filed petitions in
Continue Reading IRS Actively Seeking Information Regarding Cryptocurrency Via John Doe Summonses
New York has legalized adult use recreational marijuana for cultivation, processing, and sale in New York. The Marijuana Regulation and Taxation Act (S.854-A/A.1248) (MRTA) was signed into law by the
Continue Reading Tax Issues and the New York Marijuana Regulation and Taxation Act
In July 2019 the IRS identified post offshore voluntary disclosure program (OVDP) compliance as a campaign. The purpose of the campaign is to pursue those OVDP participants who fail to
Continue Reading Your Offshore Voluntary Disclosure May Be Long Over but the IRS May Be Looking at Your Ongoing Tax Compliance
The IRS Office of Chief Counsel announced in Issue Number IR-2020-130 that it will be making a time-limited settlement offer to certain taxpayers with pending docketed Tax Court cases involving