128 research outputs found
Putting SEC Heat on Corporate Tax Shelters and Audit Firms: Responding to Tax Risk with Sunshine, Shame and Strict Liability
Tax Shelters and the Tax Minimization Norm: How Does the Patenting of Tax Advice Transform the (Global) Playing Field
Tax Advice before the Return: The Case for Raising Standards and Denying Evidentiary Privileges
Putting SEC Heat on Corporate Tax Shelters and Audit Firms: Responding to Tax Risk with Sunshine, Shame and Strict Liability
Book-Tax Conformity and the Corporate Tax Shelter Debate: Assessing the Proposed Section 475 Mark-to-Market Safe Harbor
Putting SEC Heat on Audit Firms and Corporate Tax Shelters: Responding to Tax Risk with Sunshine, Shame and Strict Liability
Cohort Profile: Virus Watch-understanding community incidence, symptom profiles and transmission of COVID-19 in relation to population movement and behaviour
Common Sense Recommendations for the Application of Tax Law to Digital Assets
In response to the Joint Committee on Taxation’s July 2023 request for comments on application of various Internal Revenue Code sections on digital assets, we propose a consistent set of rules to apply current law to digital assets. We highlight that the underlying economics and characteristics of transactions should be the primary concern for the application of rules and the valuation of digital assets. We believe any digital asset rules should (1) treat classes of digital assets with unique characteristics differently based on their economics, (2) minimize incentives for users to engage in tax-motivated structuring of transactions, and (3) allow the Internal Revenue Service authority to react to and regulate new classes of digital assets as they are created. We do not believe that the unique features of digital assets are a challenge to applying current law or warrant special tax preferred treatment
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