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

In February 2020, the IRS announced that it would step up efforts to contact high-income taxpayers (defined as earning $100,000 or more per year), who in prior years have failed
Continue Reading The IRS Announced a New Non-Filer Initiative Over a Year Ago – Now We See the Enforcement

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 who lease or purchase aircraft face a myriad of tax issues, and aircraft can be a favorite target of both federal and state tax auditors. While the restrictions imposed
Continue Reading Non-Recourse Financing Can Imperil Tax Deductions: The Application of the Internal Revenue Code ‘At-Risk’ Rules to Aircraft Purchases

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

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