John T. Lutz
By John T. Lutz, William R. Pomierski and Andrew Granek on Jan 20, 2023
Posted In IRS Guidance
On January 13, 2023, the Internal Revenue Service (IRS) released a memorandum (CCA 202302012) concluding that a qualified appraisal is required when a taxpayer claims a charitable contribution deduction exceeding $5,000 for donated cryptocurrency. Valuations reported by cryptocurrency exchanges do not qualify as “qualified appraisals.” The memorandum is relevant to any taxpayer who has donated...
By Andrew Granek, John T. Lutz and William R. Pomierski on Feb 5, 2022
Posted In IRS Guidance
Stakers—taxpayers involved in proof of stake (PoS) validation of blockchain transactions—continue to operate in uncharted tax waters. PoS blockchains represent over half of the $1.68 trillion cryptocurrency market capitalization, with five of the top 10 PoS blockchains having a stake rate greater than 50%. Despite the remarkable growth of the PoS market in the last...
By John T. Lutz, William R. Pomierski, Le Chen and McDermott Will & Emery on Aug 6, 2021
Posted In Tax Reform
On August 1, 2021, the US Senate unveiled the draft text of the Infrastructure Investment and Jobs Act (Bill), a highly anticipated $1 trillion infrastructure package negotiated by the White House and a bipartisan group of senators. As discussed below, the Bill includes a provision (Section 80603) that, if enacted in its current form, would...
By John T. Lutz, William R. Pomierski, Kevin Spencer and McDermott Will & Emery on May 6, 2021
Posted In IRS Guidance, Tax Reform
On April 9, 2021, the Internal Revenue Service (IRS) released Chief Counsel Advice memo 202114020 (Hard Fork CCA), which details the potential tax consequences for taxpayers who held Bitcoin prior to the August 1, 2017, Bitcoin hard fork. While the Hard Fork CCA concerns the taxation of a particular cryptocurrency transaction, it has additional significance...
By McDermott Will & Emery and John T. Lutz on Dec 19, 2017
Posted In Tax Reform, Uncategorized
The Senate and House bills include provisions that place limitations on interest deductions for corporations. McDermott Tax partners Alexander Lee and John Lutz discuss several implications for US and US-based multinational corporations, including companies that will be adversely affected by the changes, debt limitations and tax efficiencies of offshore debt, and the changes in lending...