The Internal Revenue Service was aware of significant underreporting of cryptocurrency on tax returns and used one of its investigative tools (i.e., a John Doe summons) in 2016 to seek…
A recent Tax Notes article highlighted the debate surrounding a Justice Department memo proposing the reassignment of Tax Division lawyers to U.S. attorneys’ offices across the country. Experts weighed in…
Before the introduction of Bitcoin, around 2008, Wells Fargo included the phrase “Banking is necessary. Banks are not” in its 2004 annual report. The adoption of digital assets by…
The Internal Revenue Service (IRS) recently issued Private Letter Ruling (PLR) 202504006, addressing several important estate and gift tax questions related to the division of a marital trust and the…
In 2024, the IRS ramped up its focus on partnerships, including several actions before President Trump took office. However, with a new Treasury Secretary Scott Bessent confirmed, new IRS Commissioner…
Two recent criminal tax cases, one crypto focused and one less so, show how digital assets are making their way into the normal legal process involving criminal tax enforcement.
The …
Headlines and updates on sweeping changes to operations and staffing with regards to numerous federal agencies, and now implementing new tariffs, as we enter tax filing season may have people…
Gray Reed Tax Partner Joshua Smeltzer will be speaking at the 2025 International Tax Conference, hosted by The University of San Diego School of Law – Chamberlain International Tax Institute…
The IRS published final regulations on information reporting obligations for certain DeFi participants and, on the same day, the Blockchain Association, Texas Blockchain Council, and DeFi Education Fund…
Final regulations on informational reporting obligations for custodial brokers were published in the Federal Register on July 9, 2024 with an ominous note that the information reporting requirements for non-custodial…
An old German proverb states that “to change and to change for the better are two different things.” As 2024 ends, the legal and business communities who must navigate government…
Monetizing intellectual property (IP) presents complex tax challenges, particularly in determining whether proceeds are taxed at favorable capital gains rates or higher ordinary income rates. Sales of IP assets must…
On December 12, 2024, Frank Richard Ahlgren III of Austin, Texas, was sentenced to two years in prison for filing a false tax return, marking the first legal-source cryptocurrency income…