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January 26, 2023

In a recent Chief Counsel Memorandum, the IRS indicated that the rapid decline in the value of cryptocurrency alone may be insufficient, absent other factors, to claim ordinary tax losses in the year of the decline.  

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The IRS recently issued guidance effectively postponing the effective date for certain cryptocurrency broker and reporting rules.

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Is a group reorganisation to access trapped tax attributes tax avoidance?

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Treasury has issued a Notice providing much-needed guidance on various aspects of the new stock repurchase excise tax.

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The UK Government has published the final version of regulations implementing the UK's Mandatory Disclosure Rules and the repeal of the UK DAC 6 regulations. 

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The Notice provides much-needed CAMT guidance, yet leaves many open questions.

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mark.howe@cwt.com

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