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February 28, 2024

Crypto’s two calling cards, decentralization and anonymity, can lead to abuses, such as money laundering and tax evasion.  Now, the U.S. Department of Justice is unveiling a second prong of the U.S.’s pincer maneuver against these perceived abuses by directly confronting tax evasion, going beyond its historical practice of tacking tax fraud onto money laundering charges. 

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HMRC’s revised guidance on foreign entity classification considers Delaware LLCs in light of the Supreme Court decision in Anson.

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The IRS recently released proposed regulations interpreting the provisions of the Code pertaining to donor-advised funds ("DAFs"). The regulations provide needed definitions of working terms such as DAFs, Donors and Donor-Advisors, and delineate taxable distributions that are subject to certain excise taxes.

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Liberty Global has announced that it will challenge the November 2023 Tax Court finding that the company had incorrectly boosted its foreign tax credits by failing to account for gains that exceeded the total foreign loss on the sale of its stake in another company.

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