For a number of years, US taxpayers have invested in a variety of convertible virtual currencies also referred to as CVCs – cryptocurrencies being forms of CVCs that use cryptography – not always certain of the tax treatment of such investments. The Internal Revenue Service issued guidance in 2014 that briefly summarized the IRS’s view that CVCs constitute “property” for US tax purposes so that in many circumstances transactions involving CVCs would give rise […]

The rules that govern whether and when (for example, beginning of day or end of day) are complex (resembling a patchwork quilt) and frequently not intuitive. Yet tax advisers to M&A participants must be well versed in these technical rules to properly advise their clients, both as it concerns the substantive consequences of the transaction (for example, will income from the date of closing be reported on the seller’s consolidated return or be reported […]