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November 19, 2025

The IRS added new cryptocurrency tax guidance to its Thanksgiving menu this year, including a safe harbor for grantor trusts staking cryptocurrency and new broker reporting FAQs. 

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For once, a topic everyone at your Thanksgiving table might agree on: the IRS is revoking its FIRPTA look-through rule, potentially allowing for greater foreign investment in REITs.

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The UK Government has proposed draft legislation requiring all tax advisers to register with HMRC.

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France’s proposal to increase its digital services tax (“DST”) has renewed concerns about foreign taxes that unfairly target U.S. companies. The Trump administration is now signaling it may retaliate—possibly by reviving Section 899.

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The IRS plans to issue proposed regulations that would clarify that “borrow fees” paid to foreign securities lenders under market standard agreements are effectively exempt from U.S. withholding tax.

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