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On July 4, the One Big Beautiful Bill Act (OBBBA) became law and included some tweaks to the prior 2017 qualified opportunity zone (QOZ) tax legislation. The original QOZ rules, created by the Tax Cuts and Jobs Act of 2017,...more
Under the One Big Beautiful Bill Act (the “OBBBA”), the qualified opportunity zone (QOZ) program will no longer sunset on December 31, 2026, as was set to be the case prior to the act’s passage. Instead, the OBBBA makes this...more
One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more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
When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more
The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more
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
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
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
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
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
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
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
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
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
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
Virtual Currency (VC) investors continue to have accounting challenges at tax time. They are seeking to better understand and comply with their U.S. tax regulatory obligations when using VC. ...more
On September 19, 2018, the House Ways and Means Committee wrote a letter to the IRS urging the IRS to “issue updated guidance, providing additional clarity for Taxpayers seeking to better understand and comply with their tax...more
La última Notificación emitida por el IRS sobre Criptomoneda fue el Aviso 2014-21 publicado el 25 de Marzo del 2014 que brinda orientación en forma de respuestas a preguntas frecuentes (“Frequently Asked Questions”). ...more
The last Notice issued by the IRS on Cryptocurrency was Notice 2014-21 posted on March 25, 2014 providing guidance in the form of answers to frequently asked questions. ...more
La aceptación de la moneda virtual (MV) como forma de pago de bienes y servicios está creciendo. Estados como Arizona y Georgia han presentado proyectos de ley que permitirían a los contribuyentes de esos Estados pagar sus...more
La posesión de moneda virtual, también conocida como criptomoneda, es legal tanto en los EE.UU como en muchas otras partes del mundo. La forma más conocida de moneda virtual es Bitcoin. ...more
Debido al nivel sin precedentes de apreciación del valor, los inversionistas de Bitcoin, consumidores y empresas están buscando la orientación del IRS. El IRS reconoce que la "moneda virtual" se puede usar para pagar bienes...more
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
There continues to be limited Virtual Currency (VC) guidance from the US Treasury and the IRS and VC investors ought to proceed cautiously. IRS continues to make reference to Notice 2014-21 to remind Taxpayers that VC...more