Income Taxes, Reporting Requirements, Capital Gains

Proposed Rule Modifies Timing of "Hot Asset" Reporting

Holland & Knight LLP on 8/22/2025

Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more

The Corporate AMT’s Crypto Problem Poses Constitutional Hazards

Latham & Watkins LLP on 1/16/2025

Under recent accounting rule changes, unrealized crypto gains must generally be reported on income statements, but questions arise about the alignment of the new Corporate Alternative Minimum Tax with constitutional tax...more

First Stand-Alone Crypto Tax Fraud Case Leads to Guilty Plea

Cadwalader, Wickersham & Taft LLP on 10/24/2024

On September 12, 2024, the U.S. Department of Justice (“DOJ”) announced that Frank Richard Ahlgren III pleaded guilty to filing a false tax return underreporting gains from selling $3.7 million in Bitcoin. As we discussed...more

Establishing A Business Entity In India (Updated)

International Lawyers Network on 2/23/2023

1. Types of Business Entities - 1.1 Description of the types of entities available in India through which to conduct business: A foreign entity may establish a business presence in India by: • opening a liaison...more

Is Staking a Taxable Service?

Cadwalader, Wickersham & Taft LLP on 2/24/2022

On February 3, the Proof of Stake Alliance (“POSA”), a cryptocurrency industry association, issued a press release regarding recent developments in a cryptocurrency tax case, in which the IRS approved the tax refund sought by...more

New Crypto Reporting Requirements Aim to Address Tax Gap

Kohrman Jackson & Krantz LLP on 2/11/2022

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

How Will Virtual Currency Be Taxed?

Foodman CPAs & Advisors on 11/17/2021

Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Foodman CPAs & Advisors on 11/4/2021

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

Spain: Law 11/2021 implementing ATAD and other measures against fraud

Hogan Lovells on 8/5/2021

The Spanish Parliament has finally approved Law 11/2021, of 9 July, on measures to prevent and fight against tax fraud (“Law 11/2021”) which implements several aspects of Council Directive (EU) 2016/1164 of 12 July 2016...more

The IRS Is Cracking Down On Cryptocurrency Tax Reporting

Foodman CPAs & Advisors on 7/20/2021

If you’ve engaged in cryptocurrency or other virtual currency transactions worth $20,000 in any one year between 2016 and 2020, the IRS wants to hear from you. The IRS believes thousands of taxpayers are not telling the...more

The IRS is Hunting for Cryptocurrency Investors with John Doe Summonses

Gray Reed on 5/6/2021

The IRS has several tools in its arsenal to encourage compliance and audit and enforce those it believes are failing to comply. One of the most powerful tools is the John Doe summons. A regular IRS summons seeks information...more

Did You Engage In Virtual Currency Transactions In 2020?

Foodman CPAs & Advisors on 5/5/2021

Taxpayers who engaged virtual currency transactions in 2020 must answer a Yes or No Question on page 1 of Form 1040 or Form 1040-SR. The question is: “At any time during 2020, did you receive, sell, send, exchange or...more

Taxpayer Guidelines for Cryptocurrency in 2021

Gray Reed on 1/29/2021

Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper Locke on 8/17/2020

Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

Ballard Spahr LLP on 8/14/2020

On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more

IRS CI Highlights International Efforts to Tackle Cryptocurrency Abuse, Money Laundering and Tax Evasion

Ballard Spahr LLP on 12/10/2019

ABA Tax Fraud Panel to Discuss IRS CI and Crypto Criminals - The Internal Revenue Service – Criminal Investigation (IRS CI) has made it clear that it is focusing on the abuse of digital currencies to further tax evasion,...more

Virtual Currency

Herbert Smith Freehills Kramer on 12/3/2019

On Oct. 9, 2019, the Internal Revenue Service (the “Service”) issued Revenue Ruling 2019-24 concerning the tax consequences of virtual currency hard forks, as well as FAQs on the taxation of virtual currency generally. This...more

Taxpayers, have you sold, received, exchanged or acquired Virtual Currency?

Foodman CPAs & Advisors on 11/15/2019

During the month of October 2019, IRS issued Revenue Ruling 2019-24, FAQ’s on Virtual Currency Transactions and a DRAFT Form of Schedule 1, which, for the first time presents the question: “At any time during 2019, did you...more

Stick a Fork in It? IRS Issues Updated Guidance on the Tax Treatment of Cryptocurrency Forks and Provides Answers to a List of...

Polsinelli on 10/22/2019

Five years or so years ago, the Internal Revenue Service (“IRS”) provided its first, and until this week, only formal advice on the taxation of cryptocurrency transactions in Notice 2014-21. This guidance, while helpful in...more

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