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Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW

by Kevin Spencer, Simon Airey and McDermott Will & Emery | Jun 30, 2021 | IRS Guidance, Tax Reform

On June 28, 2021, McDermott held a webinar presentation titled “Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW.”

Topics during this webinar included:

How to address the tax consequences of past virtual currency transactions, including potential voluntary disclosure considerations.
How to protect your business from a US Department of Justice (DOJ) or UK investigation, including compliance updates to address this risk.
Law enforcement perspectives and updates from the IRS, DOJ and a former high-level director at HM Revenue & Customs.
How to respond to an IRS letter, including potential civil resolutions.
How to respond to a DOJ or a UK Serious Fraud Office (SFO) inquiry, summons, subpoena, search warrant or a whistleblower complaint.

A link to the webinar is available here. A link to the webinar’s slides is available here.

IRS Issues Practice Unit on Section 965 Transition Tax

by Kevin Spencer and McDermott Will & Emery | Mar 24, 2021 | IRS Audits, IRS Guidance, Tax Reform

One of the most pressing audit issues for large taxpayers today centers on the Internal Revenue Code (Code) Section 965 transition tax. The Internal Revenue Service (IRS) has designated Code Section 965 as a campaign issue and is actively auditing taxpayers’ transition tax calculations and positions, along with other tax reform items. The stakes are high, particularly given the potential to pay this tax over a period of eight years.

On March 23, 2021, the IRS released a Practice Unit that provides an overview of the Code Section 965 transition tax with references to relevant resources. Unfortunately, unlike some other Practice Units, guidance is not provided as to the type of information revenue agents should be requesting from taxpayers.

Practice Point: Practice Units are presentation-type materials compiled by the IRS as a means for collaborating and sharing knowledge among IRS employees. They provide helpful guidance to revenue agents in the form of an overview of the law in a specific area, examination tips and guidance and references to relevant resources. Although the Code Section 965 transition tax Practice Unit does not provide insights into the types of questions and information that revenue agents may seek on audit, it is still useful for taxpayers to review to understand the IRS’s perspective in this area.

Weekly IRS Roundup March 8 – March 12, 2021

by McDermott Will & Emery | Mar 17, 2021 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 8, 2021 – March 12, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

March 11, 2021: The IRS released Internal Revenue Bulletin 2021-11, dated March 15, 2021, containing the following highlights: Notice 2021-20 (Employment Tax); Notice 2021-18 (Income Tax) and Notice 2021-19 (Income Tax).

March 12, 2021: The IRS updated its campaign list to add a new campaign for compliance with section 179D and to retire the campaign for the proper treatment of economic development incentives.

March 12, 2021: The IRS issued a Practice Unit on selling a partnership interest, covering areas such as: (1) ownership changes on sale of interest to a new or existing partner; (2) proper reporting of gain; (3) section 751 assets; (4) section 1250 assets and (5) section 754 elections.

March 12, 2021: The IRS requested comments on Form 1099-C (Cancellation of Debt) regarding cancellation of debt and removal of the 36-month non-payment testing period rule.

March 12, 2021: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Samuel DiPietro in our Chicago office for this week’s roundup.

2020’s Key Tax Controversy Developments

by Kevin Spencer and McDermott Will & Emery | Dec 16, 2020 | Appellate Courts, Court Procedure Matters, IRS Appeals, IRS Audits, IRS Guidance, Transfer Pricing Resource, Trial Courts

In the face of the pandemic and all the challenges that came with 2020, tax controversy marched on. In this article, we explore several important cases, including one of the most closely watched Supreme Court cases, CIC Services LLC v. Internal Revenue Service, which raises important questions regarding the scope of the Anti-Injunction Act and impacts the ability of taxpayers to engage in preenforcement challenges to regulations.

We also look into the latest updates in the transfer pricing area, changes to the Compliance Assurance Process, what to expect during the audit of a campaign issue and more.

Read the full article.

Weekly IRS Roundup July 6 – July 10, 2020

by McDermott Will & Emery | Jul 14, 2020 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 6, 2020 – July 10, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here.

July 6, 2020: The IRS added new frequently asked questions on the treatment of grants or loans to businesses through the Coronavirus Relief Fund established by the Coronavirus Aid, Relief and Economic Security (CARES) Act. The IRS stated that a government grant is taxable because the grant generally is not excluded from the business’s gross income except in narrow circumstances. A government loan, however, generally is not included in gross income except to the extent it is forgiven. If a government forgives all or a portion of the loan, then the amount forgiven is included in gross income and taxable unless an exclusion applies. If an exclusion applies, the IRS indicated the taxpayer may lose an equivalent amount of tax attributes.

July 6, 2020: The IRS added frequently asked questions on the treatment of grants or loans to health care providers through the Provider Relief Fund established by the CARES Act. The IRS stated that payments from this fund do not qualify as a qualified disaster relief payment under section 139 of the Internal Revenue Code (IRC) and, in turn, are includible in gross income. The IRS also stated that a tax-exempt recipient generally is not subject to tax on a fund payment unless the amount is a reimbursement to an unrelated trade or business under section 511.

July 6, 2020: The IRS added content to its Large Business & International (LB&I) Active Campaign covering section 965 for individuals. In connection with the transition to a participation exemption system, certain individuals had an obligation to include in gross income (and report) their pro rata share of the untaxed earnings and profits of certain directly and indirectly owned foreign corporations. The IRS indicated it will address noncompliance through soft letters and examinations.

July 7, 2020: The IRS issued a news release reminding tax-exempt organizations that certain forms they file with the IRS are due on July 15, 2020, including Form 990. Tax-exempt organizations that need additional time to file beyond the July 15 deadline can request an automatic extension by filing Form 8868. The IRS also indicated that extending the time for filing a return does not extend the time for paying tax.

July 8, 2020: The IRS issued a news release reminding certain taxpayers to restart their tax payments by July 15. Some taxpayers took advantage of tax relief measures under the People First Initiative and did not make previously owed tax payments between March 25 and July 15. The IRS also set forth what taxpayers should do to resume their payment agreements to the IRS, including Installment Agreements, Offers in Compromise and [...]

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