Every tax season brings out the crooks and scammers trying to steal money and sensitive information using tax-related schemes, and even though we’re still a few months out from the beginning of filing season, it’s important to always be aware of threats out there and how you can combat them. Tax authorities like the IRS have countered these scams with electronic defenses that offer protection for both clients and tax preparers. Here’s a look at a few.

Much happening, even in August. This has hardly been a lazy hazy summer.

For wealthy families, the world of finance can feel like a high-stakes chess game. With increasing state and federal income tax rates, new tax laws on the horizon, and the complexities of private investments like hedge funds, finding ways to grow and transfer wealth efficiently is more important than ever. Enter life insurance—a tool not just for its traditional role of providing death benefits but as a strategic ally in tax-efficient wealth management. In particular, Private Placement Life Insurance (PPLI) offers unique advantages that make it a worthy consideration for those with sophisticated financial needs and significant liquidity.

Late on a Friday afternoon at the end of June 2024, the IRS dropped nearly 400 pages of new Digital Asset (née Cryptocurrency) Guidance. Most of it related to the forthcoming form 1099-DA. Along with the massive tome of terrible bedside reading, the service also published two new Notices and a Revenue Procedure. The Notices were about boring stuff, like temporary penalty abatement for backup withholding on digital asset transactions. This Revenue Procedure, however, will impact nearly every taxpayer that owned crypto prior to January 1, 2025. This procedure, RP 2024-28, has gone largely unnoticed thus far. On the surface, it seems like a godsend to taxpayers. Below the surface though, it is a ticking time bomb.

In late June, IRS announced it would be mailing out a time-limited settlement offer that would allow taxpayers who are haunted by an investment in a syndicated conservation easement to settle. As I write this, the terms of the settlement have leaked. They strike me as overly generous. It does seem that the syndicated easement campaign of the IRS is coming to a close.

No client’s ever happy about having to pay state income tax in addition to federal, but at least in the past that chore was straightforward: Make money in a state, probably the one where you live and work, and you owe tax on what you made if that state has an income tax. Enter the computer and the fax machine, later the modem, email and Zoom. Then enter the pandemic and widespread remote work from home that’s largely lingered after Covid faded. Cap it off with the new maneuver of moving from a high-tax state to a low-tax one but not completely severing all former work and life connections. It is any surprise, really, that states would try to squeeze tax revenue out of that using regulations still unchanged from the past? And for punishing what that state suddenly thinks are tax cheats? Do you have a client a state might be interested in? How many states? And how do you actually know?

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In Matt Metras’ excellent article on tax reporting for clients who receive settlements from the Celsius bankruptcy, he says “It’s unclear if this section could apply to digital asset bankruptcies for a variety of reasons outside the scope of this article.” Matt provides an example of the IRS’ preferred method of accounting for settlement proceeds as published on the Taxpayer Advocate’s website. Matt also notes that the TAS tax tip lacks any citations to substantial authority. It may or may not be taxpayer friendly. The articles published by many cryptocurrency exchanges are also citation free and, after a cursory review, seem geared in a larger sense toward helping exchange users account for the settlement accurately on the exchange itself. In this article, I would like to look at the forest of tax law principles that the Celsius bankruptcy settlement puts into play rather than any specific tax reporting tree. Welcome to the jungle.