Insights

Last week, I had the pleasure of attending the New York University 10th Annual Tax Controversy Forum and hearing Paul Mamo, Director of Collection in the Internal Revenue Service, speak on developments in employment tax enforcement. Over the past few years, the IRS initiated an…
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  In a 5-4 decision this morning, the Supreme Court upheld the South Dakota law requiring certain retailers to collect and remit sales tax regardless of whether the retailer had a physical presence.  The Supreme Court characterized the “physical presence” test as “unsound and incorrect”.…
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About two weeks ago, the American Institute of Certified Public Accountants – “the world’s largest member association representing the accounting profession,” – sent a letter to the Internal Revenue Service, along with a document entitled “Request for Guidance Regarding Virtual Currency”. As discussed below, in…
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  On this day in 2010, the first reported purchase of a consumer product using Bitcoin took place.  Organized on Bitcointalk forum, Laszlo Hanyecz, a programmer from Florida, traded a British man 10,000 bitcoins for two Papa John’s pizzas. The market value of the Papa…
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  A common misconception about digital assets is that they exist in a lawless virtual Wild West. While there are not any federal regulations specifically drafted for digital assets, our existing laws were intended to be broad enough to encompass new financial instruments, and a…
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  For years, taxpayers who engage in virtual currency transactions, and the lawyers and accountants who advise them, have been virtually begging the IRS for some help in terms of dealing with some of the issues that come into play when reporting those transactions for…
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  Part Three of Three: In the prior blog posts in this series, I described generally how an Initial Coin Offering (ICO) operates and discussed how the Securities and Exchange Commission views the coins or tokens generated from an ICO.  In this post, I explore…
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