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Tax partner Jim Brown and tax associate Franziska Hertel authored a recent Tax Notes Special Report article, in which they analyzed whether the commodity trading safe harbor is available to foreign investors engaging in virtual currency trades. The IRS has taken an interest in the developing tax implications and laws associated with the taxation of virtual currencies including bitcoin and BlockChain. Disputing Tax has previously reported on this topic as seen here.

In this Ropes & Gray webinar, tax partners Kat Gregor and Jim Brown and moderator Kathryn Seevers discuss the trilogy of proposed partnership audit regulations that provide rules implementing many aspects of the provisions of the Bipartisan Budget Act of 2015. The most notable set of regulations allows for “push-out” elections to be effective in pushing adjustments through tiered partnership structures. Click here to listen to the recording that includes insightful analysis of the proposed regulations.


In a recent Bloomberg article, “IRS Cops Are Scouring Crypto Accounts to Build Tax Evasion Cases,” tax attorney Jim Brown commented on the IRS’ interest in investigating taxpayers who have crypto accounts or have made unlicensed exchanges in the U.S. and overseas. Jim noted his investor clients “believe that effective regulation and law enforcement would bring legitimacy to cryptocurrency as an asset class.” Click here to read the article including more of Jim’s insight.