On Aug. 29, the IRS released a new section to the Internal Revenue Manual (IRM), 20.1.1.3.3.2.2, providing penalty relief for certain taxpayers filing 2019 and 2020 returns in response to
Continue Reading IRS Revisions to Internal Revenue Manual Clarify Who Is Eligible for Late Filing Penalty Relief
On Aug. 24, 2022, the IRS issued Notice 2022-36, which provides penalty relief to taxpayers for certain late-filed 2019 and 2020 tax returns and information returns, but this relief
Continue Reading The IRS Grants Penalty Relief for 2019 and 2020, But…
On Aug. 15, 2022, a federal court in the Central District of California authorized the Internal Revenue Service (IRS) to serve a John Doe summons on OX Labs Inc. d/b/a
Continue Reading IRS Targets Customers of Cryptocurrency Prime Dealer SFOX in Latest John Doe Summons
This GT Alert provides a high-level summary of key tax provisions of the Inflation Reduction Act, which President Biden signed into law on Aug. 16, 2022.
Continue reading the
Continue Reading The Inflation Reduction Act – Key Tax Considerations
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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