On March 20, 2020, the IRS issued Notice 2020-18, extending the April 15, 2020, due date for filing federal income tax returns and making federal income tax payments to
Continue Reading IRS Extends Income Tax Filing Deadline to July 15, 2020, and Removes Cap on Tax Payments Deferred to July 15, 2020

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

On June 21, 2019, in a unanimous decision, the U.S. Supreme Court held as unconstitutional a North Carolina statute that had been interpreted by North Carolina to mean that a
Continue Reading Effect of Kaestner on Non-California Trusts With California Beneficiaries

The Internal Revenue Service recently issued proposed regulations under Section 956 of the Internal Revenue Code (IRC) that may allow foreign subsidiaries of U.S. multinational corporate borrowers to provide additional
Continue Reading IRS Issues Proposed Section 956 Regulations Relating to Foreign Subsidiary Guarantees and Stock Pledges