Tag Archives: IRS

Regulators Weigh in on Digital Assets, Tokens, Securities, and Derivative Instruments Used in ICOs

The rise of blockchain technology ventures raising money preternaturally through initial coin offerings and token generation events (collectively, ICOs) is a capital formation disruptor, one which has and will continue to spawn considerable futures, fortunes, failures — and frauds. Blockchain-based ICOs have, through 121 offerings closed during January-August 2017, raised over $1.78 billion, with an … Continue Reading

Hints about New 871(m) Withholding Guidance

On Friday, Oct. 21, a senior official from the Internal Revenue Service said that new transition rules for the regulations for withholding on dividend equivalent payments on equity-linked derivatives under Section 871(m) will be issued in November. At a symposium sponsored by the Securities Industry and Financial Markets Association (SIFMA) in New York, Peter Merkel, … Continue Reading

New New Guidance Regarding Barrier Options

In a recently released Chief Counsel Advice Memorandum (the CCA), the Internal Revenue Service broadened its scrutiny of so-called “barrier option” transactions, which taxpayers have used to defer recognition of income and to convert ordinary income and short-term capital gain to long-term capital gain.1  The government had previously announced that it would scrutinize these transactions … Continue Reading

Wendy Li to Speak at the Annual Saratoga Institute on Equine, Racing & Gaming Law Conference

Wendy Li, shareholder of Greenberg Traurig, will be speaking at the 15th Annual Saratoga Institute on Equine, Racing & Gaming Law Conference at Saratoga Springs, New York from August 11-12. The annual program organized by the Government Law Center of Albany Law School, is dedicated to exploring the legal and public policy implications of racing … Continue Reading
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