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
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