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February 5, 2018

The IRS Accesses Bitcoin Transactions

By Erika Diebert, CPA, Tax Manager
ASL Technology Group

In November 2017 the IRS was successful in federal court in its quest to gain access to bitcoin transactions. They now have the records for any transaction worth more than $20,000, including exchanging bitcoins for dollars, and sending or receiving bitcoins to/from another user. The time frame of available information covers transactions between 2013 and 2015. The IRS is expecting a large number of bitcoin users to pay taxes owed on unreported transactions. We would be surprised if this was the end of the quest for information by the IRS. With 2016 and 2017 being big years for bitcoin activity, and other successful cryptocurrencies being left out of the November 2017 court order, a lot of possible unreported transactions are not covered by this subpoena.  (more…)

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Categories: Winter 2018
Tags: Bitcoin, Cryptocurrencies, IRS,
July 11, 2017

IRS Reissues Proposed Regulations For Centralized Partnership Audit Regime

By Franceen Borrillo, CPA, Principal

We want to make our clients aware that on June 13, 2017, the U.S. Internal Revenue Service and the Department of the Treasury re-released proposed regulations (REG 136118-15) that provide guidance on the new centralized partnership audit regime. The proposed regulations implement the new centralized partnership audit regime enacted as part of the Bipartisan Budget Act of 2015 (BBA). (more…)

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Categories: Business Taxation
Tags: BBA, centralized partnership, Franceen Borrillo, IRS, TEFRA,
By Kay Filler
•
April 11, 2017

Are Bitcoin Users Cheating on Taxes? (Or Are They Just Confounded by the Rules?)

Based on an IRS investigation, taxpayers numbering only in the 800’s in each of the years 2013 through 2015 reported a transaction description likely related to Bitcoin on the form used to report capital gains or losses from property transactions. In 2013, the IRS issued guidance to say that virtual currency transactions were property transactions, rather than currency transactions, and followed that up with practical guidance in April 2014 in their Virtual Currency Guidance, Notice 2014-21. (more…)

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Categories: The Musings of our Authors, Updates & Alerts
Tags: Bitcoin, Coinbase, IRS, Kay Filler, Virtual currency,
April 5, 2017

IRS Instructs Auditors on Issuing Summons to Foreign-Owned Businesses

In an International Practice Unit (IPU), the IRS outlined the steps its auditors should take when issuing a recordkeeping and reporting summons to a U.S. corporation that is 25% owned by a foreign shareholder.

The tax agency also elaborated on what to do when the U.S. corporation doesn’t substantially comply with the summons.

(more…)

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Categories: International Business Issues
Tags: 6038A summons, CPA, DRC, FRP, international, IPU, IRS, Sylvia Chan,
February 13, 2017

Final IRS Regs Kill Foreign Goodwill Exception and Limit Active Trade or Business Exception for Outbound Transfers of Intangibles

The IRS issued final regs that affect U.S. taxpayers who transfer property to foreign corporations in nonrecognition transactions.

The regs are aimed at preventing taxpayers from avoiding recognition of gains or income attributable to high-value intangible property by claiming that a large share of the transferred property’s value is foreign goodwill or going concern value.

The regulations contain the following changes to Section 367 of the Internal Revenue Code. They: (more…)

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Categories: International Business Issues
Tags: Exception, Foreign Goodwill, IRS, Limit Active Trade, Outbound Transfers of Intangibles, Regs,
February 9, 2017

We Are Exempt From Paying Tax, But What Do We File With the IRS?

By Samantha Ramirez, CPA, Tax Manager
ASL Nonprofit Group

For nonprofit organizations, no income tax may be due, but an annual return must be provided by certain exempt organizations in order to maintain tax-exempt status.  Tax-exempt organizations typically file a Form 990, but depending on the amount of gross receipts or the total value of assets, the organization may have options for filing a more simplified form.  Below we have outlined the requirements for each form: (more…)

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Categories: Nonprofits
Tags: Income Tax, IRS, Nonprofit, Samantha Ramirez, Tax Exempt Organizations,
February 9, 2017

Update on IRS' Proposed 2704 Regs

By Jeff Faust, CVA, Director of Valuation Services
ASL Business Valuation Services

Late last year, we wrote a few times about the looming regulations affecting valuation discounts under the IRS Proposed Section 2704 Regulations.

The comment period ended on November 1st and the public hearing in Washington D.C. was held on December 1st to a capacity crowd. Here are some quick highlights from the hearing that were published by BV Wire: (more…)

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Categories: Valuation Services
Tags: 2704 Regs, Business Valuation, IRS, Jeff Faust, Update, valuation,
January 10, 2017

IRS to Modify Regs on Some “Triangular” Reorganizations

The IRS said it plans to modify the regs relating to certain triangular reorganizations involving foreign corporations.

Specifically, in Notice 2016-73, the tax agency announced it will alter the rules affecting the treatment of property used to acquire parent stock or securities in triangular reorganizations involving one or more foreign corporations, as well as describe the consequences to persons that receive parent stock or securities in those reorganizations. (more…)

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Categories: International Business Issues
Tags: Foreign, international tax, IRS, Triangular reorganization,
November 17, 2016

Update on IRS’ Proposed 2704 Regs

By Jeff Faust, CVA, Director of Valuation Services
ASL Business Valuation Services

Earlier this year, we wrote about the looming regulations affecting valuation discounts. Now the IRS’ Proposed Section 2704 Regulations have been officially presented and they intend to eliminate discounts currently available for gifts between family members inside family controlled entities. Despite court cases and revenue rulings to the contrary, the IRS’ proposals assume that families always work together and do not keep the restrictions in place that are the basis for the minority interest discount. (more…)

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Categories: Valuation Services
Tags: 2704 Regs, discount, IRS, Jeff Faust, proposed, Services, valuation,
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