New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment
Recording of a 90-minute premium CLE/CPE webcast with Q&A
This CLE/CPE course will provide tax counsel, accountants and other advisers with a critical first look at new IRS initiatives on taxpayer compliance and reporting obligations for crypto currency (e.g. Bitcoin, Coinbase) transactions. The panel will discuss the IRS position on crypto currency as property rather than cash, analyze IRS monitoring to increase compliance, consider criminal investigations and prosecutions for failing to properly report crypto-currency transactions and define proper reporting and tax treatment for “mining” and exchanging crypto currency.
Outline
- Types of crypto currency
- Means of obtaining crypto currency
- Initial tax guidance issued in IR 2014-36
- Valuation Issues
- Tax reporting requirements for crypto currency exchanges
- Disclosure requirements for crypto-currency ownership
- Criminal investigations and prosecutions for failing to properly report crypto-currency transactions
- The use of the IRS Voluntary Disclosure policy to get into compliance and the availability of “qualified amended returns” to avoid penalties.
Benefits
The panel will review these and other key issues:
- What are the limitations on loss recognition on crypto currency transactions and exchanges?
- What are the income tax-reporting requirements for crypto currency exchanges and valuations?
- What position does IRS appear to be taking on whether crypto currency exchanges qualify for 1031 treatment, and the impact of the newly enacted Tax Cut and Jobs Act of 2017?
- What is the likely impact of the recent enforcement of the IRS “John Doe” summons to Coinbase?
- What are the disclosure requirements for crypto-currency ownership?
- How to use the IRS Voluntary Disclosure policy to get into compliance and the availability of “qualified amended returns” to avoid penalties?
Faculty
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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