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This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more
The crypto industry and government are engaging one another in various courtrooms to gain an advantage on unresolved crypto tax questions like forks and staking. In this issue, we spotlight an early Bitcoin investor...more
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
The number of virtual currency types has added to this problem. According to TIGTA, the number of virtual currencies has grown significantly since April 2020, from 5,000 to over 26,000 (420 percent) as of July 2023. The two...more
Los contribuyentes que intencionalmente han no han cumplido con obligaciones tributarias o relacionadas con impuestos pueden resolver su incumplimiento y limitar su exposición a un proceso penal presentando una solicitud a la...more
Taxpayers that have willfully failed to comply with tax or tax-related obligations may be able to resolve their non-compliance and limit their exposure to criminal prosecution by filing an application to the IRS Voluntary...more
The IRS appears to be on the verge of changing the way digital asset (i.e., cryptocurrency) transactions are reported for federal tax purposes. On April 19, 2024, the IRS issued its first draft of Form 1099-DA, the intended...more
Earlier this year the U.S. Department of Justice (“DOJ”) brought USA v. Ahlgren, its first crypto case with tax evasion allegations unrelated to another crime, demonstrating the DOJ’s willingness to pursue stand-alone crypto...more
Proposed federal legislation would move the time of taxation for rewards received from staking cryptocurrency and other digital assets to the time of sale. IRS guidance currently provides that staking rewards are taxed at the...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
Hong Kong Approves Crypto ETFs; Crypto Security, Payments Products Launch - According to recent reports, the Hong Kong Securities and Futures Trading Commission has conditionally approved the launch of the first spot...more
After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...more
El 01/22/24, el IRS le recordó a los contribuyentes que deben responder nuevamente a la pregunta sobre activos digitales 2023 en los formularios 1040 y 1040-SR y reportar todos los ingresos relacionados con activos digitales...more
On 1/22/24, the IRS reminded taxpayers that they must again answer the digital asset 2023 question on Forms 1040 and 1040-SR and report all digital asset related income when they file their 2023 federal income tax return, as...more
On January 16th, the IRS published Announcement 2024-4 (the “Announcement”), postponing certain reporting requirements for large crypto transactions which were set to go into effect for the 2024 tax year. Persons engaged in...more
Per recent transitional guidance, the IRS will not require taxpayers to report transactions involving receipt of digital assets under Section 6050I....more
In 2009, the IRS created its Global High Wealth Industry Group, known more familiarly as the “Wealth Squad.” This group starts with an examination of a “key case,” which is typically a wealthy person’s individual tax return,...more
As digital currency grows in use and acceptability, digital currency has entered into many traditional investment markets. Commercial real estate is no exception. The conversion of real estate assets to digital tokens using...more
Step into the fascinating world of virtual currencies, where digital marvels like Bitcoin and Dogecoin, have captured the attention of adventurers and investors alike. As you venture into this dynamic realm, it's important to...more
The Internal Revenue Service (“IRS”) recently issued guidance in Revenue Ruling 2023-14, holding that taxpayers who stake their cryptocurrency and receive additional units of cryptocurrency as rewards when validation occurs...more
The Internal Revenue Service (IRS) has ruled that a cash-method taxpayer that stakes cryptocurrency native to a proof-of-stake blockchain is subject to tax on additional cryptocurrency it receives as rewards when validation...more
On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which addresses the US federal income tax treatment of cryptocurrency units (commonly referred to as coins or tokens) that are received by...more
On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which provides that cryptocurrency stakers should include the value of the rewards they earn from staking in their gross income....more
The IRS recently released Revenue Ruling 2023-14, in which it addresses the tax treatment of cryptocurrency staking rewards. The IRS phases the issue as follows: If a taxpayer that uses a cash method of accounting...more
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