On June 16, 2025, the Senate Finance Committee released its own version of the tax provisions of H.R. 1, entitled the “One Big Beautiful Bill Act,” which the U.S. House of Representatives passed on May 22, 2025. The full U.S. Senate is expected to debate the Senate Proposal in the days ahead, where additional changes may be made.
Continue Reading One Big Beautiful Bill Act – Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers Abroad
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
In a significant step forward for the cryptocurrency industry, the U.S. Securities and Exchange Commission issued its first “no-action” letter (NAL) to a U.S.-based company using utility tokens created for
Continue Reading SEC Issues ‘No-Action’ Letters Allowing Sales of Utility Tokens
2018 was a year of transformation for the blockchain industry. While the market continued to see technological advancements in smart contracts, platform functionality, scalability and security, regulators took a firmer
Continue Reading Blockchain & Cryptocurrency Newsletter – Winter 2019
On June 7, 2017, the U.S. House Financial Services Committee held a hearing entitled “Flood Insurance Reform: A Taxpayer’s Perspective.” The hearing examined the National Flood Insurance Program (NFIP) and
Continue Reading U.S. House Financial Services Committee Hearing on Flood Insurance Reform and Passes Legislation
Yesterday, the U.S. Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) announced the issuance of a time-limited no-action letter stating that, from March 1, 2017
Continue Reading No Action Relief Regarding Variation Margin Rules
This year has been full of surprises in the global markets with Brexit, the Republicans’ win of the executive branch and continuing control of the legislative branch in the U.S.
Continue Reading Derivatives Update: What You Should Know As We Enter 2017
The Internal Revenue Service (the Service) issued guidance last month that will, practically speaking, make it slightly more difficult for entities to qualify as regulated investment companies (RICs) for federal
Continue Reading New Proposed RIC Regulations
It has been over two years since the IRS came out with its initial position on the tax treatment of Bitcoin and other virtual currencies, but there has yet to
Continue Reading Tax Treatment of Bitcoin Has Many Open Questions
The IRS has decided to back off its position that the 1 percent excise tax is due on a policy of reinsurance where a foreign reinsurer reinsures a policy of
Continue Reading Opportunity to File a Refund Claim for Foreign Reinsures for Retrocession Policies