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Pallav Raghuvanshi

Pallav Raghuvanshi focuses his practice on U.S. and international tax matters, with a particular emphasis on mergers and acquisitions, private investment funds, corporate restructurings, and emerging technologies such as blockchain. He regularly advises public and private companies on the tax aspects of complex cross-border M&A transactions, including taxable and tax-free acquisitions, spin-offs, and reorganizations. His work includes structuring strategies involving foreign tax credits, tax treaties, holding companies, and controlled foreign corporations.

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On Oct. 9, 2019, the Internal Revenue Service (IRS) released revenue ruling (Rev. Rul. 2019-24) and a Frequently Asked Questions (FAQs) document, which provide additional guidance on the tax treatment and reporting obligations for transactions involving virtual currency (also known as cryptocurrency). This guidance supplements the original guidance that was issued in 2014 in the form of a notice (Notice 2014-21), which provides a baseline rule that cryptocurrency is property for federal income tax purposes.

Rev. Rul. 2019-24 addresses questions related to the tax treatment of hard forks. The revenue ruling describes a hard fork as a protocol change that results in a permanent split of a new distributive ledger from a legacy or existing distributed ledger, resulting in the creation of a new cryptocurrency on the new distributed ledger in addition to the legacy cryptocurrency on the legacy distributed ledger. 
Continue Reading IRS Issues New Cryptocurrency Guidance