Event Registration - Northern Chapter VSCPA
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International Tax & Business SIG : Crypto Tax Presentation
12/16/2021
12:00 PM - 02:00 PM

Event Description
Join the International Tax and Business SIG for a meeting on the following:

Title:  Crypto Tax Presentation

Due to the decentralization of cryptocurrency transactions and the current IRS classification of cryptocurrencies as personal property, the process of compiling and reporting cryptocurrency income is akin to the same process used for foreign financial asset and income recreation.  From mining to staking to intercompany transactions, cryptocurrency is more prevalent in cross-border transactions than ever before.  Lastly, the Treasury department proposed in 2021 to update IRC 6038D to make all cryptocurrency regardless of whether it is domestic or foreign a foreign financial asset.  If this proposal is adopted it is likely that FinCEN would also require the reporting of cryptocurrency on the FBAR. 

Objectives of Presentation:
  • The Basics
    • History of cryptocurrency
    • What is cryptocurrency?
    • Types of coins, Blockchain, and timestamping
      • Non-Fungible Tokens (NFTs)
    • How is cryptocurrency created and circulated?
    • Current IRS Guidance: Notice 2014-21
      • Revenue Ruling 2019-24
      • IRS FAQs
    • Taxation of Cryptocurrency – U.S. residents vs. Non-residents
      • Tax Exempt Individuals on A, F, G, J, and M Visas
    • Section 1031 Exchanges
    • Cryptocurrency Events
    • Valuation and Documentation
  • Advanced Issues
    • Cryptocurrency as method of payment
      • Employee receiving wages or salary
      • Contractor receiving self-employed income
      • Merchant receiving payment for goods or services
    • Investors (accounting method), traders, and dealers
    • Miners (solo, pool, and cloud)
      • Cryptocurrency and QBI
    • Proof of Stake Protocol, i.e., Staking
    • Indirect Investment in Crypto Assets
    • US Tax Treaty Application with Cross-Border Crypto Assets
    • Executive incentives, charitable contributions, retirement accounts Initial Coin Offerings (ICOs), Securities Token Offering (STO), and Initial Exchange Offering (IEO)
    • Value Added Tax, Sales Tax, Withholding Tax
    • Gift, Estate, and the US Exit Tax
  • Reporting & Compliance
    • US Individual Income Tax Return Page 1 Question
    • Foreign financial asset reporting (FBAR/8938)
    • Department of Justice “John Doe” summons on Coinbase, Kraken, and Payward Ventures Inc.
    • Department of Justice Money Laundering Probe of Binance
    • IRS Virtual Currency Compliance Campaign (2018)
    • IRS LB&I Campaign Letters 6173, 6174, and 6174-A
    • Options for non-compliance including IRS Amnesty Programs

Benefits:  2 hours of CPE(offered to Northern Chapter VSCPA members; guests pay $25)

You must answer 75% of the pop-up questions (please make sure your browser accepts pop-ups) throughout the training.
You must attend a minimum of 100 minutes. Only the live version of the webinar is eligible.


Location: Virtual, Zoom meeting

Time:  12:00pm - 2:00pm

Presenter: Mishkin Santa, J.D., LL.M, TEP ∙ International Tax Director

Presenter's Bio:
Mishkin Santa, J.D., LL.M, TEP, is a Principal and International Tax Director at The Wolf Group (Washington, DC, Fairfax, VA, and New York, NY), specializing in cross-border tax matters.  As a former attorney with the U.S. Internal Revenue Service (IRS) Chief Counsel, he is well-positioned to guide clients on a range of reporting and disclosure issues. 
 
Mishkin’s practice areas include: Cryptocurrency, Offshore Voluntary Disclosure, Exit Tax, Foreign Pensions, Foreign Trusts, Non-Resident Alien, and International Organization Employee Taxation.