Popular, Tax Liability, 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

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

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on 8/24/2023

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...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

The Year in Tax Law – 2022 Popular Reads on JD Supra

Beacon Insights by JD Supra on 1/5/2023

A look at some of the most widely read tax-related updates and commentary published on JD Supra during 2022....more

Today in Tax: How NFT Sellers Can Prepare for State Taxes

Miller Nash LLP on 9/27/2022

Pennsylvania and Washington became the first two states to offer official guidance on how their existing tax regimes apply to nonfungible token (NFT) transactions. Their approaches offer two blueprints for other states to...more

The Inflation Reduction Act — Incentives for Clean Motor Vehicles and Refueling Property

Orrick, Herrington & Sutcliffe LLP on 8/8/2022

The Inflation Reduction Act of 2022 (the “IRA”) released by U.S. Senate Democrats on July 27, 2022 would, if enacted, provide a number of financial incentives to encourage the purchase of electric and hydrogen fuel cell...more

States Turning Eyes to Taxation of Cryptocurrency and Non-Fungible Tokens (NFTs)

Cadwalader, Wickersham & Taft LLP on 7/21/2022

As the IRS ponders its approach to taxing cryptocurrency and NFTs, states are increasingly imposing taxes on some digital asset transactions, including the use of cryptocurrencies...more

[Webinar] Your Legal Guide to NFTs, the Metaverse, and Web3 - June 14th - 16th, 1:00 pm - 2:00 pm ET

Venable LLP on 6/9/2022

Non-fungible tokens (NFTs), the metaverse, and Web3 bring with them a host of new legal challenges in such areas as IP, securities law, tax, and advertising. As NFTs revolutionize the digital landscape and global economy, it...more

Crypto Trading Safe Harbor – We’re On Our Own

Cadwalader, Wickersham & Taft LLP on 5/25/2022

The District of Columbia Bar Tax Legislative and Regulatory Update Conference, a two-day conference on tax legislative and regulatory developments, included a one-and-a-half hour panel on taxation of cryptocurrencies and...more

Cryptocurrency: The Basics of Tax Treatment and Recognition

Gray Reed on 4/1/2022

Cryptocurrencies might, simplistically, be defined as virtual currencies that use cryptography to secure transactions which are digitally recorded on a widely distributed ledger. The ledger technology uses independent...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

Fiscalité internationale : Décisions de la Cour suprême du Canada

Blake, Cassels & Graydon LLP on 1/6/2022

La Cour suprême du Canada (la « CSC ») a récemment rendu d’importantes décisions dans deux différends qui portaient sur des questions de fiscalité internationale. Dans l’affaire Canada c. Alta Energy Luxembourg S.A.R.L., 2021...more

International Tax Issues at the Supreme Court of Canada

Blake, Cassels & Graydon LLP on 12/20/2021

The Supreme Court of Canada (SCC) recently released two important decisions relating to international tax issues. The SCC provided meaningful guidance on the interpretation of one of Canada’s bilateral tax treaties and the...more

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on 9/7/2021

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...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

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

Internal Revenue Service Clarifies Tax Rule for Marijuana Industry

Partridge Snow & Hahn LLP on 10/15/2020

The Internal Revenue Service (IRS) issued guidance on Thursday, September 10, 2020, to marijuana businesses. The new guidance does not change existing IRS rules, but briefly explains the rules for reporting income, paying...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

IRS Confirms PPP Loan Forgiveness Not Taxable

Pullman & Comley, LLC on 10/5/2020

Under general income tax principles, when a borrower has its indebtedness forgiven, the borrower recognizes income in the forgiven amount. Under the CARES Act, however, Congress made clear that forgiveness of a Paycheck...more

The IRS Provides Some Good News to Oregonians During a Time When Positive News Is Rare – News Releases OR-2020-23 and IR-2020-215

Foster Garvey PC on 9/18/2020

When we thought times were bad enough with the COVID-19 pandemic and widespread social unrest in our country, the West Coast, including the Pacific Northwest, was struck with unprecedented wildfires and massive windstorms,...more

Treasury and IRS are Aiming to Provide Greater Clarity on International Tax Reporting

Foodman CPAs & Advisors on 8/7/2020

On July 14, 2020, the US Treasury Department and the IRS released a proposed redesigned partnership form for tax year 2021 (filing season 2022). The two proposed forms SCHEDULE K-2 (Form 1065) and Schedule K-3 (Form 1065) are...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

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