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
The Washington state Department of Revenue (WDOR) in July 2022 published detailed guidance on the sales tax consequences of non-fungible token (NFT) sales, the first such guidance in the
Continue Reading Sales Tax on NFTs: Washington State Guidance Blazes Trail Other States May Follow
Tax Practice Shareholder Pallav Raghuvanshi is quoted in an April 29 Thomson Reuters Checkpoint article titled “The Long Read: Catching Up With Crypto.”
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Continue Reading Pallav Raghuvanshi Quoted in Thomson Reuters Article, ‘The Long Read: Catching Up With Crypto’
On Feb. 15, 2022, the IRS announced revisions to Form 14457, the Voluntary Disclosure Practice Preclearance Request and Application. The longstanding Voluntary Disclosure Practice is a way for taxpayers who
Continue Reading IRS Announces Revisions to the Application Form for Voluntary Disclosures with New Provisions for Cryptocurrency, Employment Tax, and Estate, Gift and Generation-Skipping Transfer Tax
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
The IRS has published guidance stating that pre-2018 swaps among Bitcoin, Ether, and Litecoin are not eligible for 1031 tax-free exchange treatment. This means that investors who made swaps among
Continue Reading IRS Says No Tax-Free Exchange Treatment for Swaps of Bitcoin, Ether, and Litecoin
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
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 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