The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more
4/30/2025
/ Affiliates ,
Cloud Computing ,
Digital Assets ,
Final Rules ,
Foreign Affiliates ,
Income Taxes ,
International Tax Issues ,
Multinationals ,
Proposed Rules ,
Regulatory Requirements ,
Service Contracts ,
Software ,
Taxation ,
Third-Party Service Provider ,
U.S. Treasury
On July 31, 2023, the IRS issued Revenue Ruling 2023-14, which sets forth the IRS’s position as to when certain staking “rewards” are taxable income.
The Ruling analyzes a fact pattern where a cash method taxpayer “stakes...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation -
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Find yourself on the cutting-edge of international tax law, with...more
8/31/2022
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Cross-Border ,
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Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
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Webinars
On October 9, 2019, the IRS released Revenue Ruling 2019-24, which provides guidance with respect to hard forks and airdrops of cryptocurrency, and new frequently asked questions (FAQs), which provide guidance on other...more
10/14/2019
/ 1099s ,
Blockchain ,
Capital Gains ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
Fair Market Value ,
Income Taxes ,
IRS ,
New Guidance ,
Peer-to-Peer ,
Popular ,
Revenue Rulings ,
Transfer Taxes ,
Virtual Currency ,
W-2
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
12/13/2018
/ Allocation of Funds ,
Banking Sector ,
Books & Records ,
CFC ,
Controlled Foreign Corporations ,
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Financial Institutions ,
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Foreign Corporations ,
Foreign Tax ,
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IRS ,
Multinationals ,
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Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Royalties ,
Stocks ,
Subpart F ,
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Tax Cuts and Jobs Act ,
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Tax Planning ,
Tax Rates ,
Tax Reform ,
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Taxable Distributions ,
U.S. Treasury