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 on the potential impact on tax enforcement, with some arguing that decentralization could weaken compliance efforts, while others saw opportunities for increased efficiency at the
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 traditional banks has been slow, primarily because of regulatory obstacles and a lack of legislative guidance that would help ease fears and reduce risks. Both
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 subsequent disclaimer of a surviving spouse’s interest in a portion of the trust. This ruling provides valuable insights into the tax treatment of trust divisions
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 Billy Long named but not yet confirmed, federal funding cuts, a federal hiring freeze, and employee reductions at both IRS and the Department of Justice
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 United States Department of Justice announced, in April 2024, that Roger Keith Ver, known by his followers as “Bitcoin Jesus,” was indicted on fraud
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 even more on edge than years prior at the sight of a letter from the IRS or any chatter about taxes in general. If the
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, on Monday, February 17, and Tuesday, February 18, 2025.
Joshua’s session will cover Cross-Border Tax and Financial Fraud in 2025 and Beyond, where he will
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 filed a lawsuit in the Northern District of Texas claiming violations of the Administrative Procedures Act and the U.S. Constitution.
My previous article provided a
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 brokers (i.e. Decentralized Finance or DeFi) would be forthcoming. The first effective date for those final regulations would be January 1, 2025. On December 27
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 scrutiny are seeing the signs of change in the regulatory landscape on the horizon. The pencils for redrawing the lines of government involvement in economic