Tag: Cottage Savings

Liberty Global – Economic Substance Case

Cases, Court of Appeals, Income Tax, Tax, Tax Controversy, Uncategorized

Tax lawyers routinely test proposed transactions against the technical requirements of the Internal Revenue Code. The Tenth Circuit’s recent decision in Liberty Global, Inc. v. United States[1] is a reminder that literal compliance may not always end the analysis. In Liberty Global, the court applied the codified economic substance doctrine to deny a claimed §…
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Tax Effect of Protocol Updates to Blockchain-Based Cryptocurrency

Chief Counsel Advice, Cryptocurrency, Income Tax, Regulatory

A recent Chief Counsel Advice Memorandum (“CCA”) discusses certain tax consequences pertaining to a taxpayer owning cryptocurrency native to a blockchain that undergoes a protocol upgrade. CCA 202316008. In the hypothetical scenario discussed in the CCA, a hypothetical blockchain, very similar to Ethereum, underwent a change in the method in which it approved and processed…
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