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Hone Maxwell

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

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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

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

Ballard Spahr LLP on

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

Mayer Brown

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

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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

Cadwalader, Wickersham & Taft LLP

IRS Says Crypto Protocol Changes Are Not Taxable

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

Cadwalader, Wickersham & Taft LLP

Back to the Future ... Cryptocurrency Tax Reporting

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

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

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

Foodman CPAs & Advisors

The IRS Is Cracking Down On Cryptocurrency Tax Reporting

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

Bowditch & Dewey

Cryptocurrency Tax Update

Bowditch & Dewey on

The IRS continues its campaign against cryptocurrency investors and traders who evade income taxes on currency gains. As we wrote in 2016, the IRS was successful in compelling Coinbase, a large digital currency exchange, to...more

A&O Shearman

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

A&O Shearman on

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

McAfee & Taft

IRS announces relief for certain Form 1094/1095 reporting requirements

McAfee & Taft on

In a similar move as in previous years, the IRS has issued relief from certain Form 1094-C and 1095-C reporting requirements under the Affordable Care Act relating to employee health plans, as well as relief from certain...more

Polsinelli

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

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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

Foodman CPAs & Advisors

U.S. Financial Institutions and FATCA

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

Foodman CPAs & Advisors

Willfulness and IRS Foreign Account Reporting Requirements

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

McDermott Will & Schulte

What is the Significance of Virtual Currency Not Being Taxed as Currency?

Virtual currencies are not currently accepted as the legal tender or “fiat” currency of any country. In the United States, the IRS has stated its view that convertible virtual currency is property, subject to the general tax...more

Foodman CPAs & Advisors

IRS issues FATCA Relief but not for All

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

Orrick - On the Chain

IRS Hints at Form 8938 Requirements for Reporting Crypto Assets Held at a Foreign Exchange

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With the emergence of digital assets, the question has arisen whether digital assets held in “wallets” in foreign exchanges need to be reported on Internal Revenue Service (IRS) Form 8938, Statement of Specified Foreign...more

McDermott Will & Schulte

Weekly IRS Roundup December 9 – 13, 2019

McDermott Will & Schulte on

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

Foodman CPAs & Advisors

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

Foodman CPAs & Advisors on

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

Polsinelli

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

Polsinelli on

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

Foodman CPAs & Advisors

The “J5” is on to Cryptocurrencies

The Organisation for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. The result of this “call to action” was the establishment of an...more

Foodman CPAs & Advisors

No relief in sight for US Expatriates worldwide as Duplicative Reporting Requirements Continue to Burden US Expatriate Taxpayers

The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. ...more

Foodman CPAs & Advisors

Many are now looking for IRS Guidance on Virtual Currency

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Due to its unprecedented level of value appreciation, Bitcoin investors, consumers and businesses are looking for IRS Guidance. IRS recognizes that “virtual currency” may be used to pay for goods or services, or be held for...more

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