Popular, Reporting Requirements, Tax Planning

Why Some International Entrepreneurs Use U.S. LLCs Without Paying U.S. Tax

Hone Maxwell on 6/4/2025

In the increasingly global world of online business, it’s not unusual for entrepreneurs, freelancers, and consultants to seek a business structure that supports international operations, offers stable banking options, and...more

IRS Changes Course on Income Tax Impact of Employee Retention Credit

Ballard Spahr LLP on 4/9/2025

On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

New Administration Action on Cryptocurrency Tax Regulations

Seward & Kissel LLP on 2/21/2025

The Seward & Kissel Tax Group has collected some data and intelligence about what crypto tax changes we may see this year. President Trump aims to assess and revive cryptocurrency regulations via executive order, Congress...more

Corporate Transparency Act, Part 2: Exempt Status, Physical Office, Dissolved and Tribal Entities, and Beneficial Ownership...

PilieroMazza PLLC on 10/21/2024

The Corporate Transparency Act (CTA), which came into effect on January 1, 2024, has significant implications for government contractors, tribal entities, and commercial businesses. If you formed an entity before January 1,...more

Final Tax Rules and Transitional Guidance for Broker Reporting

Seward & Kissel LLP on 8/29/2024

The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

Mayer Brown on 7/18/2024

In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more

Business Taxation of Hedging Transactions Part I: Hedging Risks

ASKramer Law on 4/5/2024

Enterprise Risk Management is widely used in many industries and businesses. Risk managers use increasingly sophisticated approaches, methods, analytics, and frameworks to manage complex, interrelated, and interconnected...more

IRS Says Crypto Protocol Changes Are Not Taxable

Cadwalader, Wickersham & Taft LLP on 5/25/2023

On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more

Back to the Future ... Cryptocurrency Tax Reporting

Cadwalader, Wickersham & Taft LLP on 1/26/2023

The cryptocurrency industry may be breathing a sigh of relief following the release of recent IRS guidance on cryptocurrency tax reporting, which effectively postpones the January 1, 2023 effective date of the digital asset...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

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

Beware of FATCA Notices of Default After FATCA Certification Deadlines!

Foodman CPAs & Advisors on 10/29/2020

Under FATCA, an Event of Default (EOD) will occur if an Entity fails to perform required material obligations with respect to the due diligence, verification, withholding, or reporting FATCA requirements, or if the IRS...more

IRS Releases Additional Tax Guidance on the Transition from Interbank Offered Rates

A&O Shearman on 10/20/2020

On October 12, 2020, the Internal Revenue Service issued Revenue Procedure 2020-44 (the Revenue Procedure) providing additional guidance related to the transition from an interbank offered rate (IBOR) to another replacement...more

IRS Advises that Virtual Currency Received in Exchange for Microtasking is Subject to Ordinary Income Tax and Self-Employment Tax

Polsinelli on 10/8/2020

As discussed in previous blog entries , the IRS has been engaged in an ongoing campaign intended to address noncompliance related to the use of crypto currencies, including a virtual currency compliance campaign spearheaded...more

U.S. Financial Institutions and FATCA

Foodman CPAs & Advisors on 8/7/2020

Little is written regarding FATCA and U.S. Financial Institutions (FI). That said, U.S. FIs have FATCA responsibilities. In the absence of permitted exceptions, FATCA requires U.S. FIs that make payments of most types of...more

Willfulness and IRS Foreign Account Reporting Requirements

Foodman CPAs & Advisors on 7/29/2020

The IRS Mission Statement states that: “the taxpayer’s role is to understand and meet his or her tax obligations”. Taxpayers fill out their own returns under a “self-assessment voluntary reporting system” because the...more

The OVDP is now the VDP

Foodman CPAs & Advisors on 6/24/2020

There was an IRS termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. On November 20, 2018, following the OVDP notice of termination, there was a release of a Memorandum announcing the...more

IRS issues FATCA Relief but not for All

Foodman CPAs & Advisors on 1/17/2020

On September 6, 2019, IRS announced Relief Procedures for Certain Former Citizens. These are procedures for certain persons who have relinquished, or intend to relinquish, their United States citizenship, who wish to come...more

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Schulte on 12/31/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

Weekly IRS Roundup December 9 – 13, 2019

McDermott Will & Schulte on 12/18/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

A Little Extra: IRS Ups ACA Reporting Relief

Ballard Spahr LLP on 12/5/2019

Once again, the IRS has extended the deadline for furnishing Forms 1095-B and 1095-C to individuals. Reporting penalties will not apply to those who meet the applicable deadlines and complete the forms in good faith....more

Virtual Currency: The Taxman is Coming

Holland & Knight LLP on 12/4/2019

Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...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

IRS Issues Sends Letters to Over 10,000 Taxpayers with Cryptocurrency Transactions Without Providing Anticipated Guidance

Polsinelli on 8/24/2019

On July 26, 2019, the IRS announced that it was in the process of sending letters to over 10,000 taxpayers with a history of cryptocurrency transactions by the end of August, noting that the letters were sent to taxpayers...more

Blockchain and Tax: Navigating Uncertainty

Jones Day on 5/2/2019

Virtual currencies (often called cryptocurrencies) such as bitcoin are perhaps blockchain's best-known application. As these and other blockchain-based digital assets become more common, and attract more regulatory and...more

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