On January 13, the U.S. Treasury and Internal Revenue Service released long-awaited proposed regulations governing the treatment of certain features of tax-free corporate spin-off and split-off transactions.
On December 27, 2024, the Treasury and the IRS released final regulations on reporting requirements for DeFi participants.
The most recent UK decision on “unallowable purpose” reiterates that the First-tier Tribunal will consider all the evidence before it.
On January 14, 2025, Treasury and the IRS published final regulations that identify certain micro-captive insurance transactions, as well as transactions substantially similar thereto, as either listed transactions or transactions of interests.
Treasury is on track to meet its New Year’s resolutions early, just in time for the Trump administration to take charge.
The U.S. Tax Court issued an opinion declining to revisit its holding from 13 months earlier that a partner’s formal status as a “limited partner” under state law does not determine whether the partner is eligible for the “limited partner exception” for Self-Employment Contributions Act (“SECA”) purposes.
On December 12, 2024, the DOJ announced that a taxpayer was sentenced to two years in prison for filing a false tax return underreporting gains from selling $3.7 million in Bitcoin.