New Developments in Cryptocurrency - Reporting and Enforcement
Wednesday, June 9, 2021
10:00 AM to 11:40 AM

Speaker: Michel Stein, Esq
2 Federal Tax Law Hours
IRS: 18QC1-T-01469-21-O
CTEC: 1000-CE-4868

Session Description:
The program will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and reporting income and gain on cryptocurrency (e.g., Bitcoin) transactions. We will discuss the IRS position on cryptocurrency as property rather than cash, analyze IRS efforts to increase compliance and define proper reporting and the tax treatment for hard forks, "mining" and exchanging cryptocurrency. We will address recently released IRS Revenue Ruling 2019-24 and the updated FAQs regarding the taxation of cryptocurrency, with a particular focus on the recent IRS enforcement initiatives to identify virtual currency activity, how the IRS soft letter campaign fits into the voluntary disclosure practice and the risks of criminal prosecution related to unreported and improperly reported cryptocurrency transactions.

Knowledge Level: Basic

Learning Objectives:

#1: Discuss various types of cryptocurrency and exchanges.

#2: Valuation issues, tax reporting requirements for cryptocurrency exchanges. Taxpayer disclosure requirements for cryptocurrency ownership.

#3: Likelihood of criminal investigations and prosecutions for failing to properly report cryptocurrency transactions.

Michel Stein, Esq

MICHEL R. STEIN is a principal at Hochman Salkin Toscher Perez, specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters.

Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. Government's ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. He has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamline or otherwise.

Throughout his career, Mr. Stein has represented thousands of individual, business and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters as well as with possible assertions of fraudulent conduct and in defending criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayer's and their advisors around the world.

Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. Mr. Stein received his LL.M. in Taxation from the NYU School of Law and graduated from the University of California, Hastings College of the Law. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court. He is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization.