Legal Alert: An incomplete picture: Democratic senators release “framework” for international tax overhaul
Posted on Aug 31, 2021 in International Tax, Legal Alerts
On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The legislative language is generally in line with the International Tax Overhaul proposals first released by the Senators on April 5, 2021. The draft legislation includes some provisions...
Last ditch effort to narrow reporting requirements on crypto denied; alternative avenues still remain for industry to reduce scope of new rules
Posted on Aug 19, 2021 in News
The Senate approved the Infrastructure Investment and Jobs Act (H.R. 3684) (the Act), advancing the new legislation to the House for consideration. In an effort to raise revenue for part of the overall $1 trillion in infrastructure spending, the Act contains language that would amend federal law on digital asset information reporting by expanding reporting requirements for brokers,...
Legal Alert: Rev. Proc. 2021-34, IRS guidance for implementing the final Section 451 regulations
Posted on Aug 17, 2021 in Legal Alerts
On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). In a lengthy 70-page piece of guidance, the revenue procedure not only provides accounting method changes and the terms and conditions to comply with the Final Regulations by its effective date, (tax years beginning on or after...
Legal Alert: Budget Reconciliation Act I – Setting the Stage: Senate provides slim details of Budget Resolution Agreement
Posted on Aug 11, 2021 in Legal Alerts
On Monday, August 9, the Senate released the framework for the Fiscal Year 2022 Budget Resolution Agreement, and subsequently passed the resolution in a 50-49 partisan vote on August 10. The resolution now goes to the House, as both chambers of Congress must pass the final reconciliation bill. The framework totals $3.5 trillion in Budget Reconciliation instructions. The instructions...
New proposed legislation adds information reporting requirements for digital assets
Posted on Aug 5, 2021 in News
The proposed Infrastructure Investment and Jobs Act would explicitly impose information reporting on cryptocurrency transfers in the same way information reporting is required on transfers of stock or securities. Therefore, both sales price and “basis” – typically original acquisition price – would be reported to the IRS, which would inform the IRS of a taxpayer’s sale of...