December 11, 2019

Taxpayers request guidance on a moving target.

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Revenue Ruling 2019-24 addresses the tax treatment of cryptocurrency hard forks and airdrops. 

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In a recent article, Cadwalader tax partner Jason Schwartz explores how direct lending funds can use the Ireland-U.S. income tax treaty to make loans in the United States without being subject to U.S. federal income tax.

Although narrower than taxpayers had hoped, the IRS' new CFC guidance does eliminate some traps for the unwary.

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When can UK taxpayers rely on HMRC guidance?

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The IRS has announced that it intends to narrow a "debt recast" rule that has concerned tax practitioners for the past three years.

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