Bryan C. Skarlatos participated in the panel titled "Life Cycle And Tax Implications Of A Cryptocurrency" at the ABA Section of Taxation 2018 May Meeting
This panel followed the life cycle of a cryptocurrency and the tax issues that arise at each stage including the formation of the entity issuing the token, solicitation of investors via a SAFT, token launch and acceptance on an exchange, and tokens held for investment purposes and used similar to fiat currency.
The U.S. Tax Court and the First Circuit recently reached opposite conclusions in two similar cases on the taxability of individual retirement account contributions, but the Tax Court may be hard-pressed to follow the appellate court’s more taxpayer-friendly decision if it means weakening an important tool for the Internal Revenue Service to enforce tax laws.
Bryan C. Skarlatos chaired the program "Nuts And Bolts Of Tax Penalties 2018: A Primer On The Standards, Procedures & Defenses Relating To Civil & Criminal Tax Penalties" at the 2018 Practising Law Institute (PLI)
This one-day seminar was a unique opportunity to review the various tax penalties that can be imposed, the standards and transactions that can trigger penalties and sanctions, the procedures the Internal Revenue Service must follow to assess penalties and the defenses that can be asserted.