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January 22, 2025

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.

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On December 27, 2024, the Treasury and the IRS released final regulations on reporting requirements for DeFi participants.

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The most recent UK decision on “unallowable purpose” reiterates that the First-tier Tribunal will consider all the evidence before it.

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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.

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Treasury is on track to meet its New Year’s resolutions early, just in time for the Trump administration to take charge.

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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.

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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. 

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