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November 28, 2023

During a recent IRS hearing, various representatives from the crypto industry, including crypto trade associations, voiced concerns over the scope and content of the proposed crypto broker reporting regulations. The extent to which these comments shape the final regulations remains to be seen.

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Liberty Global Inc. avoided tax from the sale of a Belgian subsidiary by claiming a dividends received deduction for the entire amount of $2.6 billion in gain. The government challenged this result on economic substance and step transaction grounds.

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When is the purpose of a company, or a group of companies, the avoidance of tax?

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On November 13, 2023, the NYSBA Tax Section published comments to the proposed crypto broker reporting regulations.  In its report, the NYSBA provided 10 recommendations to Treasury addressing various aspects of the regulations.

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New proposed rules for the energy investment tax credit aim to enhance clarity, laying the groundwork for the implementation of the transferability provisions for clean energy tax credits.

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Plenty of ink has been spilled by tax experts cautioning about the potential ramifications of Moore v. United States, but when the Joint Committee on Taxation added REMICs to the list of tax provisions that could be invalidated by a ruling in favor of the Moores, that really raised some eyebrows.

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