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New IRS Cryptocurrency Enforcement Program

NEW IRS CRYPTOCURRENCY ENFORCEMENT PROGRAM

Cost Free
Presentation Length 1.0 hour

Recorded DateAugust 14, 2019
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

The IRS is sending out more than 10,000 letters between now and the end of August reminding taxpayers that taxes must be paid on their cryptocurrency transactions.  The letters are targeted to taxpayers based on information the IRS has received from enforcement efforts (e.g., the summons to Coinbase) and data analytics. There are three variations of the IRS letters (6173, 6174, and 6174-A) with varying degrees of warnings. The IRS urges taxpayers receiving these letters to take immediate action.

The speaker will discuss:


  • A brief overview of the nature of cryptocurrency

  • The tax rules and IRS guidance related to cryptocurrency

  • The IRS’s new enforcement programs related to cryptocurrency

  • Options for responding to the IRS cryptocurrency warning letters

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Joshua Wu, a former Deputy Assistant Attorney General (DAAG) for Appellate and Review in the Tax Division of the US Department of Justice (DOJ), counsels and advocates for companies and high-net-worth individuals on all aspects of tax controversies and litigation. Mr. Wu advises on tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, and tax-exempt controversies. He brings a unique knowledge base and skill set to his clients, drawing on his experience both in senior leadership roles in the DOJ’s Tax Division and private practice.
 
Most recently, when Mr. Wu served as DAAG, he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. He also represented the United States in oral appellate arguments, evaluated and approved significant civil settlement offers, and furnished advice to the Tax Division’s trial sections in complex tax cases.
 
Mr. Wu previously served as DAAG for Policy and Planning, where he led the Office of Management and Administration (OMA) at DOJ. In that role, he led the operational functions of the Tax Division and led the Office of Legislation and Policy, which works with the Department of Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives. Before his government service, Mr. Wu was a partner at a large international law firm. 

About Our Presenter

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Clark Hill is a multidisciplinary international law firm that draws on its attorneys’ comprehensive industry and policy knowledge, deeply held shared values, and a global network of premier firms and advisors to provide effective legal solutions and client-service excellence. One of the top 100 firms in the United States — with over 600 attorneys and professionals in 25 offices across the nation, as well as offices in Dublin and Mexico City, we are a committed partner to a diverse range of leading brands, forward-thinking businesses, public entities, nonprofit organizations and individuals. Our significant presence in Washington, DC, and our deep government relations and public affairs experience at every level help ensure that our clients’ voices are heard in the development of federal and state regulatory policy and legislation.