Publications Archives

Crypto In Bankruptcy: Tax Apocalypse For Celsius Customers?

By Garrett L. Brodeur Bloomberg Tax Management Memorandum January 30, 2023 Introduction: In the aftermath of a series of bankruptcy filings by major cryptocurrency companies, a recent ruling on an ownership dispute in the bankruptcy case of Celsius Network LLC has placed certain interest-bearing account

Coffee, NFTs, And Noncompliance?

By Garrett L. Brodeur and Mahima Chaudhary Tax Notes Federal November 28, 2022 Abstract: In this article, Brodeur and Chaudhary examine Odyssey, a new blockchain-based rewards program from Starbucks, and its potential tax pitfalls for unwary customers. Digital assets are becoming mainstream, and commercial enterprises

The Lawyer’s Guide To Cryptocurrency: Ethical, Tax, And Reporting Issues With The Receipt Of Cryptocurrency As Payment For Legal Services

By Christopher M. Ferguson Journal of Tax Practice & Procedure Fall 2022 Introduction: The cryptocurrency (“crypto”) economy appears here to stay. Notwithstanding the recent “crypto winter,” the use of, and trading in, bitcoin and other crypto-currencies has exploded over the last several years. Once viewed

New Crypto Tax Question Foreshadows IRS Enforcement Priorities

By Garrett L. Brodeur Tax Notes Federal September 5, 2022 Abstract: In this article, Brodeur argues that recent changes to the Form 1040 cryptocurrency question highlight an area in which the IRS sees significant enforcement potential and foreshadow a continued shift in the agency’s priorities.

Tips On Qualified Small Business Stock Exclusions

By Stephen Josey Law360 Tax Authority July 27, 2022 On May 27, the Internal Revenue Service provided much-needed guidance to taxpayers and tax professionals regarding the scope of the qualified trades or businesses requirement for claiming the qualified small business stock, or QSBS, exclusion. As

Old Dog, New Tricks? The New York FCA and Crypto-Tax Compliance

By Garrett L. Brodeur and David Taylor Tax Notes State July 25, 2022 Abstract: In this article, Brodeur and Taylor examine the New York Attorney General’s intention to use the state’s False Claims Act to ensure cryptocurrency tax compliance, which they argue raises important tax

Tax Implications of Dobbs for Interstate Travel Expenses to Obtain Abortions

By Caroline Rule Tax Notes Federal July 18, 2022 Abstract: In this article, Rule provides an overview of how an employer may offer tax-deductible, abortion-related travel benefits after the recent Dobbs decision. Taxes were almost certainly not the first thing that came to mind when

How The Wealthy Commit International Tax Evasion: A Case Study

By Jay R. Nanavati and Jas Singh Tax Notes Federal Volume 175, June 20, 2022 In the 1994 movie The Shawshank Redemption, prisoner Andy Dufresne asks head prison guard Byron Hadley if he trusts his wife. At first, the viewers and Hadley think that Dufresne

‘Flat Sum’ Settlements: An ‘End Run’ Around New York’s Reporting Requirements?

By Garrett L. Brodeur The CPA Journal, Tax Practice & Procedure Column March/April 2022 Issue In computing a state resident’s adjusted gross income for personal income tax purposes, New York, like many states, starts with the individual’s federal adjusted gross income and makes certain additions

The First-Time Abatement Policy—Harsh Realities And Strategic Considerations

By Garrett L. Brodeur ABA Tax Times May 2022 Issue First-Time Abatement The IRS implemented a first-time abatement (FTA) policy in 2001 to provide relief from penalties in a single year for failure to file, failure to pay, or failure to deposit under certain circumstances.