Taxation
Ca. Tax Lawyer VOLUME 33, ISSUE 1, DECEMBER 2024
Content
- 2023-2024 Executive and Standing Committee Leaders
- An Overview of the History of California Residency
- ARE 1031 DROP & SWAP REAL ESTATE EXCHANGES IN JEOPARDY IN CALIFORNIA?
- Committee Quick Points
- Message From the Chair
- Perfecting the Informal Refund Claim (No Malpractice, Please)
- Table of Contents
- The Office of Tax Appeals Sources An Individual Partner's Distributive Share of Partnership Gain Using Corporate Apportionment and Allocation Rules In the Appeal of Smith
- Three Taxation Section Awards Presented At the Annual Tax Conference In Palm Springs In November 2023
- A Critique of the Cryptic Rules For Taxing Crypto
A CRITIQUE OF THE CRYPTIC RULES FOR TAXING CRYPTO
By James Creech, Dennis Leonard and Justin Miller1
In this article, the authors argue that the lack of formal guidance regarding digital currency has created a surplus of misinformation and suggest that the Internal Revenue Service (IRS) and U.S. Department of the Treasury (Treasury) offer more informal guidance and implement a new voluntary disclosure program for crypto assets to allow noncompliant taxpayers to become compliant with reduced penalties.
INTRODUCTION
Despite the exponential increase in the use of digital currency in recent years, the IRS and Treasury have issued little official guidance since 2019.2 Since then, the technology that underlies cryptocurrency has evolved and tested the limits of how the existing guidance can be applied.