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January 25, 2024

Recent IRS guidance postpones certain reporting requirements for businesses receiving large crypto transactions until future regulations are promulgated. 

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Tax credit sales are underway with the launch of the IRS’s new registration portal on December 22.  The IRS released detailed guidance on several of the tax credits that are eligible for sale, restoring confidence that a robust market for these credits will develop in the near term.

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A narrow interpretation of the financial services VAT exemption is given by UK’s Supreme Court.

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In December, Treasury and the IRS issued proposed regulations updating the standard for determining when a debt instrument held by certain banks and insurance regulated entities will be conclusively presumed to be worthless for tax purposes.

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Recent remarks from an IRS counsel indicate that upcoming guidance on the limited partner exception from self-employment tax may incorporate a functional analysis test that evaluates the extent to which a limited partner functions as a passive investor.

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The ABA Tax Section published comments and recommendations on the proposed regulations applicable to brokers of digital assets.  

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Plenty of ink has been spilled by tax experts cautioning about the potential ramifications of Moore v. United States, and we admit that we may have contributed to the hysteria.  As we await the decision, here are the specific arguments being presented before the Supreme Court.

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