Terence McAllister Terence McAllister

Subscribe to Terence McAllister's Posts
Terence H. McAllister focuses his practice on US and international tax matters.

IRS Releases Guidance on Cryptocurrency Hard Forks

By , , , and 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...

Continue Reading

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...

Continue Reading

Reasonable Cause for E-Filing Errors?

By and on Mar 7, 2019
Posted In Court Procedure Matters, IRS Guidance, Tax Reform, Uncategorized

Tax return filing season is fast approaching, and taxpayers big and small are preparing to file their returns. A recent US Court of Appeals for the Fifth Circuit decision, Haynes v. United States, No. 17-50816 (5th Cir. Jan. 29, 2019), indicates that many of those taxpayers will face uncertainty if their returns are late due...

Continue Reading