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The Symposium will cover topics including: - What are the tax and accounting structuring, compliance and enforcement considerations when tokenizing assets? - Onboarding private fund processes on-chain, where are we...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
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
Due to the anonymity of non-fungible tokens’ (“NFTs”) transactions, sellers face practical difficulties in determining whether or not they should charge Spanish Value Added Tax (“VAT”) to the buyers on sales through online...more
While the number of cryptocurrencies and other blockchain-based assets continue to grow, the IRS’s published guidance is inadequate in addressing how to tax these new digital assets and transactions involving them....more
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
Jarrett Case Raises New Questions on How to Report Cryptocurrency “Staking” Rewards - While the IRS has not specifically addressed the taxation of staking rewards, they have indicated a willingness to treat these rewards in...more
NFTs—or “nonfungible tokens”—are everywhere. What was once seen as a collectors’ item for crypto geeks and LeBron James TopShop fanatics is now gaining popularity with a much wider audience. Take the recent example of the...more
Against the backdrop of rapidly evolving blockchain technology, the IRS has oftentimes been slow to update its related tax guidance, leaving participants in the blockchain ecosystem uncertain about their tax obligations....more
DeFi, or decentralized finance, has experienced unprecedented growth over the last few years, resulting in a market cap of approximately $85 billion as of October 2021. Built on blockchain technology and cryptocurrency, DeFi...more
Our firm has written extensively on the topic of cryptocurrency. Indeed, we have even designated an entire resource page on our website to this always interesting and constantly evolving topic...more
Background on NFTs - With the market for nonfungible tokens (NFTs) exploding, NFTs attached to art, music, video clips, tweets and other digital collectibles have sold for significant sums: An NFT of an animated flying...more
What do professional athletes, punk artwork and digital kittens have in common? They are all part of the expansion of valuable collectible assets using cryptocurrency and blockchain technology. You can collect digital items...more
Are you ready for the world of cryptocurrency? It is increasingly becoming an important—but complex—wealth transfer topic in estate planning. In order to properly advise clients and manage their portfolios, accountants and...more
Many crypto entrepreneurs are seeking to build decentralized networks in which a token serves as a means of exchange on, or provides access to a function of the network. In the course of building out the network, they need...more
On 10/9/19, IRS issued Rev. Rul. 2019-24 addressing the issues of a Taxpayer having gross income under § 61 of the Internal Revenue Code as a result of a hard fork of a cryptocurrency that the Taxpayer owns if the Taxpayer...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
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
On October 9, 2019, the Internal Revenue Service (IRS) issued Revenue Ruling 2019-24, which describes when a "hard fork" results in adverse tax consequences, and a set of frequently asked questions (the FAQs), which provide...more
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
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
El Jefe de Investigación Criminal del IRS, Don Fort, declaró recientemente: "Es posible utilizar Bitcoin y otras Criptomonedas de la misma manera que las cuentas bancarias extranjeras para facilitar la evasión de impuestos"....more
Possession of virtual currency, also known as cryptocurrency, is legal in the U.S. as well as many other parts of the world. The most well-known form of virtual currency is Bitcoin. There are other virtual currencies that...more