On August 5, 2021 Senate Finance Committee Chairman Ron Wyden and Senator Sheldon Whitehouse introduced proposed legislation (the “Ending the Carried Interest Loophole Act,” or the “Proposal”) that would substantially change the U.S. federal income tax treatment of partnership interests issued in exchange for services, commonly known as carried interests, and potentially other types of
IRS Intensifies Efforts on Cryptocurrencies
In a recent International Financial Law Review article, tax partner Jim Brown provides insight on how the IRS has joined tax authorities from the UK, Canada, the Netherlands and Australia to create the Joint Chiefs of Global Tax Enforcement, a sign regulators are getting serious about cryptocurrency. Jim notes that there are questions on how
Virtual Currencies and the Commodity Trading Safe Harbor
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
Three Valentines from the IRS
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
IRS Investigators Seek to Build Tax Evasion Cases Against Crypto Accounts
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