Two recent federal district court decisions evaluated whether the process historically utilized by the Department of Treasury and the Internal Revenue Service (“IRS”) to issue guidance satisfied the requirements of the...more
Just 10 years ago, only your millennial, techie cousin had ever heard of, let alone purchased, any cryptocurrency. Fast forward to 2021, and the volume of cryptocurrency transactions has grown to $15.8 trillion....more
10/6/2022
/ Bitcoin ,
Blockchain ,
Common Reporting Standard (CRS) ,
Cryptocurrency ,
Digital Assets ,
Ethereum ,
FATCA ,
FIFO ,
Foreign Financial Institutions (FFI) ,
Internal Revenue Code (IRC) ,
IRS ,
OECD ,
Popular ,
Reporting Requirements ,
Virtual Currency
Recent correspondence between a group of U.S. Senators and the Department of the Treasury appears to have eased the significant concerns expressed by the digital asset sector regarding the scope of the new broker reporting...more
Through its recent passage of the Infrastructure Investment and Jobs Act (the “Act”), Congress resolved an open question regarding the extent to which cryptocurrency transactions should be subject to information reporting...more
In August, the Federal Bar Association Section on Taxation held an informative roundtable on the IRS’s new large partnership compliance or LPC program. One of the speakers, Maria Dolan with the IRS’s Large Business &...more
10/4/2021
/ Audits ,
Bipartisan Budget Act ,
Enforcement ,
FATCA ,
FDAP ,
FIRPTA ,
IRS ,
Large Business & International Division (LB&I) ,
Partnerships ,
Pass-Through Entities ,
Tax Avoidance ,
TEFRA
Our inaugural issue focuses on a truly transnational and important rule of law: the attorney-client privilege and related protections against disclosure. While this is a topic common to all areas of law, the tax arena at...more
5/7/2021
/ Attorney-Client Privilege ,
Audits ,
Cost-Sharing ,
Disclosure ,
Dual Purpose ,
Financial Reporting Council (FRC) ,
IRS ,
Litigation Privilege ,
Microsoft ,
Stocks ,
UK ,
US v Microsoft ,
Valuation
MOFO SALT 2018 YEAR IN REVIEW: CONTINUED SUCCESS IN A CHANGING STATE TAX WORLD -
Following the enactment of the Federal Tax Cuts and Jobs Act in late 2017, many interesting state tax issues emerged concerning states’...more
In Sales and Use Tax Bulletin 2019-01, the Pennsylvania Department of Revenue asserts that remote sellers with economic nexus must collect and remit Pennsylvania sales tax. The Bulletin is effective July 1, 2019....more
On January 4, 2019, the Pennsylvania Department of Revenue issued Corporation Tax Bulletin 2019-01 taking the position that receipts from hedging transactions, including those of a securities dealer, should be excluded from...more
Until recently, retail sellers of goods and services were not required to collect sales tax unless they had a physical presence in a state. Sellers that operated primarily from one location and offered goods and services via...more
Benjamin Franklin famously said that nothing in this world is certain except death and taxes. And the certainty of taxes leads to the inevitability of audits. Whether you are preparing for your first State tax audit or your...more
On October 25, 2018, in Downs Racing, LP v. Commonwealth, a unanimous Pennsylvania Supreme Court partially reversed the Commonwealth Court and held that royalty fees for intellectual property are not subject to sales and use...more
Many states and localities are concerned that the proliferation of streaming services is shrinking tax revenues previously received from sales of traditional forms of entertainment. Those concerns are not unfounded. The...more
On June 28, 2018, the Pennsylvania Legislature enacted legislation allowing companies to depreciate bonus depreciation property placed in service after September 27, 2017 pursuant to the normal federal depreciation rules...more
The Pennsylvania Department of Revenue (the “Department”) has been taking aggressive positions to source sales of services to Pennsylvania for corporate tax purposes. For tax years beginning on or prior to December 31, 2013,...more
In This Issue:
- Where’s Walden? Finding Protection under the Due Process Clause
- Upcoming Speaking Engagements
- CFCs and Subpart F Income in a California Water’s-Edge Election and What’s Wrong with the Apple...more
In This Issue:
Ringing in the New Year: Issues from 2013 That Will Likely Impact 2014; Upcoming Speaking Engagements; Defending Against Penalties; and Dueling “Doing Business” Interstate-Commerce Exemptions:...more
In This Issue:
“Occasional Sales” and Single Sales Factor Apportionment in California; Upcoming Speaking Engagements; State Taxation of Financial Institutions; Applying the True Object Test to Determine the Taxability...more
In This Issue:
Factor Representation: Is It Unconstitutional for a State to Have It Both Ways?; Upcoming Speaking Engagements; Expanded California Sales and Use Tax Exclusions for Advanced Manufacturing Projects; and...more