Cryptocurrency Tax Compliance: Tax Filing Requirements, Managing IRS Examinations
Tax Treatment of Digital Currency, Exchange Transactions, Investments, Drop-Ins, Hard Forks, Soft Forks, and More
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel, accountants, and other advisers with a critical look at recent IRS enforcement actions on taxpayer compliance and reporting obligations for cryptocurrency transactions. The panel will discuss the IRS' position on the tax treatment of cryptocurrency, analyze IRS monitoring to increase compliance, consider criminal investigations and prosecutions for failing to report cryptocurrency transactions accurately, and define proper reporting and tax treatment for "mining" and exchanging cryptocurrency. The panel will also discuss tactics in managing IRS examinations and audits.
Outline
- Recent IRS enforcement actions
- Valuation issues
- Tax reporting requirements for cryptocurrency exchanges
- Disclosure requirements for cryptocurrency ownership
- Criminal investigations and prosecutions for failing to properly report cryptocurrency transactions
Benefits
The panel will review these and other key issues:
- What recent actions have the IRS taken regarding cryptocurrency tax compliance?
- What are the income tax reporting requirements for cryptocurrency exchanges and valuations?
- What are the limitations on loss recognition on cryptocurrency transactions and exchanges?
- IRS' position on whether cryptocurrency exchanges qualify for 1031 treatment and the impact of the enacted tax reform
- What are best practices in managing an IRS examination?
Faculty
Evan J. Davis
Principal
Hochman Salkin Toscher Perez
Mr. Davis joined the firm in 2016 after more than 20 years in the public sector as a trial lawyer with extensive... | Read More
Mr. Davis joined the firm in 2016 after more than 20 years in the public sector as a trial lawyer with extensive civil and criminal trial and appellate experience in both federal and state courts. He and his cases have been profiled by the New York Times, Wall Street Journal, Los Angeles Times, People Magazine, as well as national legal publications such as Tax Notes and Law360. Mr. Davis represents individuals and closely held entities in criminal tax investigations and prosecutions, civil tax controversy and litigation, sensitive-issue or complex civil tax examinations and administrative tax appeals, and federal and state white-collar criminal investigations. He represents numerous cryptocurrency clients worldwide on civil and criminal tax matters, speaks frequently on cryptocurrency, criminal tax, and Bank Secrecy Act issues, deals with civil and criminal cannabis-related tax issues, and handles civil and criminal unreported foreign account and foreign-entities investigations and disclosures. In the appellate arena, Mr. Davis has argued cases before the Ninth Circuit Court of Appeals as both a prosecutor and defense counsel and was trial and appellate counsel on the attorney-client privilege case In re Grand Jury, which the U.S. Supreme Court heard in 2023. Mr. Davis frequently lectures on many topics throughout the country both in the private sector and as a federal prosecutor.
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Michel R. Stein
Principal
Hochman Salkin Toscher Perez
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For... | Read More
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc.
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Steven (Steve) Toscher
Managing Principal
Hochman Salkin Toscher Perez
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions... | Read More
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions of the U.S. Department of Justice and the Office of the United States Attorney, numerous state taxing authorities and in federal and state court litigation and appeals. Mr. Toscher enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. He has considerable experience as lead counsel in defending criminal tax fraud investigations (both administrative and grand jury investigations) as well as in defending criminal tax prosecutions (both jury and non-jury). Mr. Toscher’s tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, sales taxes and property taxes. He is routinely involved in sensitive issue or complex civil tax examinations and administrative appeals on behalf of wealthy individuals and their closely held entities as well as large corporations involving both domestic and foreign tax related issues.
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