On May 3, 2023, the United States Tax Court held in ES NPA Holding, LLC v. Commissioner, T.C. Memo. 2023-55, that the taxpayer’s receipt of interests in a partnership in exchange for services rendered to the sole owner of the...more
This blog post summarizes recent federal bills that have been introduced (but not yet passed), proposals by the Biden Administration, and guidance issued by the Internal Revenue Service with respect to the taxation of digital...more
5/2/2023
/ Biden Administration ,
Brokers ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Digital Assets ,
Excise Tax ,
FATCA ,
Green Book ,
Infrastructure Investment and Jobs Act (IIJA) ,
IRS ,
New Guidance ,
Non-Fungible Tokens (NFTs) ,
Proposed Legislation ,
Reporting Requirements ,
Stablecoins ,
Virtual Currency
On October 21, 2021, the Internal Revenue Service (the “IRS”) released Notice 2021-56 (the “Notice”), which sets forth the additional requirements a limited liability company (“LLC”) must satisfy to obtain a determination...more