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May 24, 2023

In Notice 2023-34, the IRS clarified that the recognition of cryptocurrency as legal tender in some countries will not alter the treatment of cryptocurrency as property, and not currency, for U.S. federal income tax purposes.

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A recent U.S. Tax Court case provided welcome confirmation that a set of common equity compensation structures falls within the IRS’s safe harbor for grants of profits interests in partnerships.

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A recent IRS memorandum provides that certain cryptocurrency protocol changes are not taxable events. The memorandum may be particularly relevant for holders of cryptocurrency that undergo protocol changes, including holders of Ether impacted by the recent Ethereum Merge.

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HMRC has successfully opposed two restructuring plans in as many months.

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The UK government announced a package of tax policy proposals on 27 April 2023.

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