UBS Account Holders and French Tax Authorities

On July 26, 2019, the Swiss Federal Supreme Court rendered a groundbreaking judgment in the field of administrative assistance in tax matters. Reversing a 2018 ruling of the Swiss Federal Administrative Court, the Supreme Court decided that information regarding tens of thousands of UBS account holders presumed to have tax residence in France could be transmitted to the French tax authorities. The decision was rendered by a panel of five judges, who held public deliberations—a … Read More

IRS Sends Second Letters to Cryptocurrency Holders

Some cryptocurrency investors are receiving a second letter from the Internal Revenue Service telling them that their federal tax returns don’t match the information received from virtual currency exchanges, a new approach in the agency’s increased monitoring of the industry. The letters acknowledge that trading exchanges, not the taxpayers, may have made the errors. The letters are a fresh signal that the IRS is increasing its focus on cryptocurrency tax compliance, after first being slow … Read More

IRS Letters 6173, 6174 and 6175

The IRS is sending out letters 6173, 6174, and 6174a to advise taxpayers of their tax obligations with respect to transactions involving virtual currency, which includes crypto-currency and non-crypto virtual currencies. IRS Letter 6174-A advises the taxpayer that the IRS has information that the taxpayer had one or more accounts containing virtual currency but may not have properly reported any transactions properly. The letter advises the taxpayer to file an amended or delinquent return, write … Read More

State’s Collecting Sales Tax on Cryptocurrency Sales

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Don’t Avoid IRS Cryptocurrency Letters

Individuals who received letters from the IRS recently should take the agency’s warnings seriously about reporting their cryptocurrency assets. Failure to take the letters seriously could mean big penalties down the road, said Evan Fox, practice leader in the Digital Asset Advisory Services group at Berdon LLP in New York. “The IRS likely after this will not be lenient if they happen to catch people.” The agency in July began sending letters to more than … Read More

French Banks May Close Accounts of 40,000 Accidental Americans

The president of the French banking association the Federation Bancaire Francais Laurent Mignon has written to finance minister Bruno Le Maire laying out his concerns about international banking accord FATCA – which obliges banks across the world to notify US tax authorities of all accounts owned by US citizens. It was intended to combat tax avoidance, but has ended up snaring many US citizens of modest means who live in other countries, as well as … Read More

IRS Sending Letters to Cryptocurrency Holders

The IRS has begun the audit process of people they expect aren’t correctly reporting the income and tax they owe on virtual currency transactions. The IRS recently sent out lLetter 6174-A, that states: “We have information that you have or had one or more accounts containing virtual currency but may not have properly reported your transactions involving virtual currency, which include cryptocurrency and non-crypto virtual currencies.” The letters inform taxpayers they may be subject to … Read More

IRS Begins Audits on Cryptocurrency Cases

The IRS is beginning to audit taxpayers with cryptocurrency assets, an agency official said. “In our exam operations, we’re starting to work those cases,” Mary Beth Murphy, commissioner of the Internal Revenue Service Small Business/Self-Employed Division, said June 20 at a tax controversy forum hosted by the New York University School of Professional Studies. She also said that SB/SE is coordinating with the agency’s Large Business and International (LB&I) Division in determining how to proceed … Read More