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Finding John Doe, Part II: IRS Secures Another Victory to “Root Out” Virtual Currency Tax Noncompliance


By , , and on May 7, 2021
Posted In IRS Guidance, Tax Reform

The Internal Revenue Service (IRS) has scored another significant victory in its rapidly increasing virtual currency tax enforcement efforts. On May 5, 2021, the US District Court for the Northern District of California entered an order authorizing the IRS to serve a John Doe summons on popular cryptocurrency exchange, Payward Ventures Inc. d/b/a Kraken (Kraken)....

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DOJ and IRS’ Analysis of Crypto Records and Work with Private Experts and International Partners Leads to Arrest


By and on Apr 30, 2021
Posted In IRS Guidance, Uncategorized

US law enforcement continues to make no secret of their efforts to work closely with experts and overseas partners to prosecute those involved in virtual currency transactions who attempt to rely on its purported anonymity to commit financial crimes. Tuesday’s arrest of Roman Sterlingov, a dual citizen of Russia and Sweden and alleged operator of...

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Finding John Doe: IRS Steps up Enforcement Efforts to Take the Anonymity Out of Virtual Currency


By on Apr 21, 2021
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Trial Courts

The Internal Revenue Service (IRS) is stepping up its virtual currency enforcement, and taxpayers who have engaged in a cryptocurrency transaction should immediately assess any potential tax implications as the IRS has recently issued two John Doe summonses to popular exchanges. These are the first it has issued in about three years, sending a very...

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Despite NOL Carrybacks, IRS Continues to Deny Refunds of Section 965 Transition Tax Overpayments


By on Apr 29, 2020
Posted In Tax Refunds, Uncategorized

In a series of frequently asked questions (FAQs) addressing the interaction of recently enacted net operating loss (NOL) carryback provisions and section 965, the IRS stated that taxpayers may not receive a refund of any section 965 tax payment unless and until the payment exceeds the “entire income tax liability for section 965.” The IRS...

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IRS Postpones Virtually All Deadlines Until July 15, 2020, in Response to COVID-19


By , , and on Apr 10, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would have had a filing, payment or other deadline between April 1, 2020, and July 15, 2020, now qualify for an extension. Access the full article.

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IRS to Temporarily Adjust Operations and Key Compliance Functions


By and on Mar 26, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

On March 25, 2020, the Internal Revenue Service (IRS) announced a new People First Initiative designed to provide relief to taxpayers on a variety of issues ranging from easing payment guidelines to postponing compliance actions in light of the challenges caused by the Coronavirus (COVID-19) pandemic. The initiative’s projected start date is April 1, 2020, and it...

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IRS Provides Some Relief from Tax Payment (But Not Filing) Deadlines Due to COVID-19


By , , and on Mar 19, 2020
Posted In IRS Guidance, Uncategorized

On March 13, 2020, President Trump issued an emergency declaration that directed Secretary Mnuchin to provide appropriate relief from tax payment deadlines to Americans who have been adversely affected by the COVID-19 pandemic. In response to this direction, the IRS issued Notice 2020-17. The Notice declares that all taxpayers have been affected by the emergency...

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The Tax Impact of Recent Federal Actions Relating to COVID-19


By and on Mar 18, 2020
Posted In IRS Guidance, Uncategorized

On March 13, 2020, President Trump signed a Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (the “Stafford Act”). By invoking the Stafford Act, the President provides the Internal Revenue Service (IRS) and US Department of the Treasury (the...

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When the IRS Says It’ll ‘Meet You in Paris’: Recent Trends & Developments in Outbound US Exchange-of-Information Techniques


By on Oct 3, 2019
Posted In IRS Guidance, Uncategorized

The Internal Revenue Service is looking for your international tax data—that is, if the IRS doesn’t already have it. With the rollout of the Foreign Account Tax Compliance Act (FATCA) and other automatic exchange-of-information (EOI) procedures, the IRS is now receiving—and making use of—a large amount of international tax information about US taxpayers. In an...

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Courtney Dunbar Jones and Emin Toro Confirmed to Tax Court


By on Aug 7, 2019
Posted In Court Procedure Matters, Trial Courts, Uncategorized

On August 5, 2019, the Senate confirmed Courtney Dunbar Jones and Emin Toro as nominees to the US Tax Court in a voice vote before leaving for August recess. Jones and Toro will now each serve a 15-year term. President Trump had initially nominated each candidate in 2018, but the Senate was not able to...

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