The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of
Continue Reading IRS and Treasury Department Finalize Qualified Foreign Pension Funds Regulations
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.
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Continue Reading The Inflation Reduction Act – Key Tax Considerations
The Fourth Circuit in Cook v. United States held that federal tax penalty assessments and the payments the debtor made were not voidable fraudulent transfers that generally allow debtors to
Continue Reading 4th Circuit Holds Tax Penalty Obligations Are Not Voidable Fraudulent Transfers
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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
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
On March 31, 2021, President Joe Biden unveiled a $2 trillion infrastructure and economic recovery plan (American Jobs Plan) to strengthen the post-pandemic economy. The American Jobs Plan
Continue Reading Corporate Tax Hikes for Biden’s Infrastructure Plan
Under the Tax Cuts and Jobs Act of 2017, the new Section 163(j) generally limits a taxpayer’s deduction of any business interest expense to 30% of the taxpayer’s adjusted taxable
On Oct. 9, 2019, the Internal Revenue Service (IRS) released revenue ruling (Rev. Rul. 2019-24) and a Frequently Asked Questions (FAQs) document, which provide additional guidance on the tax treatment and reporting obligations for transactions involving virtual currency (also known as cryptocurrency). This guidance supplements the original guidance that was issued in 2014 in the form of a notice (Notice 2014-21), which provides a baseline rule that cryptocurrency is property for federal income tax purposes.
Rev. Rul. 2019-24 addresses questions related to the tax treatment of hard forks. The revenue ruling describes a hard fork as a protocol change that results in a permanent split of a new distributive ledger from a legacy or existing distributed ledger, resulting in the creation of a new cryptocurrency on the new distributed ledger in addition to the legacy cryptocurrency on the legacy distributed ledger.
Continue Reading IRS Issues New Cryptocurrency Guidance
Recently proposed IRS regulations would significantly affect tax on income from international cloud transactions and electronic transfers of digital content. Accordingly, CFOs should review the structure of agreements involving such
Continue Reading IRS Aims to Catch Up to Tech Advancements