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On May 5, 2021, a California District Court issued an order authorizing the IRS’s John Summons against Kraken, a popular cryptocurrency exchange. The summons seeks to obtain information on US taxpayers who conducted at least $20,000 in total transactions for each year from 2016 to 2020. This is… Read More

In a recent Chief Counsel Advice Memorandum, the IRS made clear that receipt of a “new” cryptocurrency (following a Hard Fork) results in gross income to the taxpayer (equal to its Fair Market Value) immediately upon the taxpayer’s dominion and control over the new cryptocurrency. It is an… Read More

In May 2021, an IRS Official clarified that the IRS will seize cryptocurrencies and sell them to satisfy tax collection if a taxpayer fails to meet his tax obligations. Because cryptocurrency is treated as property for tax purposes, just like other property assets, the same seizure collection measures… Read More

In March 2021, in U.S. v. Gentges, the court held that a taxpayer filing an erroneous tax return – despite his carelessness in reviewing it before he signed it – was nevertheless per se evidence of reckless conduct giving rise to the higher Willful FBAR penalties. Therefore, it… Read More

While cannabis (or marijuana) is legal in some states for medical and recreational use, cannabis is still a Schedule 1 narcotic for federal purposes. Because of this, Section 280E of the Internal Revenue Code applies. Section 280E disallows deductions or credits “for any amount paid or incurred during… Read More

In a case of first impression, the Court of Appeals for the Ninth Circuit ruled that the IRS can impose only one non-willful penalty under 31 USC 5321(a)(5)(A) when an untimely, but accurate, Report of Foreign Bank and Financial Accounts (FBAR) is filed, no matter the number of… Read More