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Crypto Assets And The Problem Of Tax Classifications, Eric D. Chason Feb 2023

Crypto Assets And The Problem Of Tax Classifications, Eric D. Chason

Faculty Publications

To date, Internal Revenue Service (I.R.S.) guidance on cryptocurrencies has been thin. When the I.R.S. has issued guidance, it occasionally mishandles the technical details (such as confusing air drops and hard forks). More personnel (and personnel with greater technical expertise) would allow the I.R.S. to keep pace with the explosive growth of cryptocurrency. Nevertheless, the I.R.S. could better leverage its existing resources by focusing on select issues and seeking enabling legislation from Congress. Specifically, the I.R.S. should focus on crypto issues occurring on a system-wide basis and not requiring taxpayer-specific considerations.

For example, determining whether Bitcoin is a “security” under …


Advising Partners And Partnerships Under The New Centralized Partnership Audit Rules: The Need To Amend Partnership And Llc Operating Agreements (Powerpoint), Jerald D. August Nov 2018

Advising Partners And Partnerships Under The New Centralized Partnership Audit Rules: The Need To Amend Partnership And Llc Operating Agreements (Powerpoint), Jerald D. August

William & Mary Annual Tax Conference

No abstract provided.


An Overview Of Partnerships (Powerpoint), Ari Berk, Drew Tidwell Nov 2018

An Overview Of Partnerships (Powerpoint), Ari Berk, Drew Tidwell

William & Mary Annual Tax Conference

No abstract provided.


The Natural Property Rights Straitjacket: The Takings Clause, Taxation, And Excessive Rigidity, Eric Kades Apr 2018

The Natural Property Rights Straitjacket: The Takings Clause, Taxation, And Excessive Rigidity, Eric Kades

Faculty Publications

Natural property rights theories have become the primary lens through which conservative jurists and scholars view the Constitution’s main property rights provision, the Takings Clause. One of their most striking arguments is that progressive income taxation — applying higher tax rates to higher incomes — is an unconstitutional taking of wealthy taxpayers’ property. This has become part and parcel of well-established battle lines between conservative property rights advocates and their liberal counterparts. What has gone unnoticed is that the very same argument deployed against progressive taxation also deems regressive taxation — applying lower tax rates to higher incomes — an …


A Progressive Federal Tax Credit For State Tax Payments, Eric Kades Jun 2017

A Progressive Federal Tax Credit For State Tax Payments, Eric Kades

Popular Media

No abstract provided.


Giving Credit Where Credit Is Due: Reducing Inequality With A Progressive State Tax Credit, Eric Kades Dec 2016

Giving Credit Where Credit Is Due: Reducing Inequality With A Progressive State Tax Credit, Eric Kades

Faculty Publications

No abstract provided.


Federal Tax Update (Powerpoint), Stephen L. Owen Nov 2016

Federal Tax Update (Powerpoint), Stephen L. Owen

William & Mary Annual Tax Conference

No abstract provided.


Taxing Losers, Eric D. Chason May 2016

Taxing Losers, Eric D. Chason

Faculty Publications

The U.S. tax system, like most in the world, benefits capital gains in two ways. Investors can defer paying tax until they "realize" any gain (typically by sale) rather than when the gain simply occurs via rising prices. Additionally, individual investors pay a lower, preferred rate on their long-term capital gains as compared to their other ordinary income (such as compensation or business profits).

However, investors face a burden with respect to their capital losses. Rather than allowing for unlimited capital loss deductions, the Code largely forces investors to match their capital losses against their capital gains. Limits on capital …


Recent Developments In Virginia Taxation, Craig D. Bell, William L.S Rowe Nov 2015

Recent Developments In Virginia Taxation, Craig D. Bell, William L.S Rowe

William & Mary Annual Tax Conference

No abstract provided.


Recent Tax Developments In Virginia: 2013-2014, Craig D. Bell, William L.S Rowe Nov 2014

Recent Tax Developments In Virginia: 2013-2014, Craig D. Bell, William L.S Rowe

William & Mary Annual Tax Conference

No abstract provided.


I Want Out – Tax Considerations In Exiting A Partnership, James B. Sowell Nov 2013

I Want Out – Tax Considerations In Exiting A Partnership, James B. Sowell

William & Mary Annual Tax Conference

No abstract provided.


Partnership Current Developments, Robert J. Crnkovich, Steven M. Friedman Nov 2013

Partnership Current Developments, Robert J. Crnkovich, Steven M. Friedman

William & Mary Annual Tax Conference

No abstract provided.


Representing Clients In Audits And Controversies In Today’S Tax Enforcement Environment, Craig D. Bell, William L.S Rowe Nov 2013

Representing Clients In Audits And Controversies In Today’S Tax Enforcement Environment, Craig D. Bell, William L.S Rowe

William & Mary Annual Tax Conference

No abstract provided.


Introduction To M&A Tax: S Corporations And Section 336(E), Robert G. Mcelroy, William M. Richardson Nov 2013

Introduction To M&A Tax: S Corporations And Section 336(E), Robert G. Mcelroy, William M. Richardson

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Virginia Taxation, Craig D. Bell, William L.S Rowe Nov 2013

Recent Developments In Virginia Taxation, Craig D. Bell, William L.S Rowe

William & Mary Annual Tax Conference

No abstract provided.


A Tax Hike Liberals And Conservatives Should Both Like, Nathan B. Oman Jan 2013

A Tax Hike Liberals And Conservatives Should Both Like, Nathan B. Oman

Popular Media

No abstract provided.


Wage Taxes And Compensating S Corporation Officers And Members Of Llcs And Llps, John W. Lee Nov 2011

Wage Taxes And Compensating S Corporation Officers And Members Of Llcs And Llps, John W. Lee

William & Mary Annual Tax Conference

No abstract provided.


Compensating Employees And Employee Owners, And Avoiding Problems With Payroll Tax And Executive Compensation Audits, Mary B. Hevener Nov 2011

Compensating Employees And Employee Owners, And Avoiding Problems With Payroll Tax And Executive Compensation Audits, Mary B. Hevener

William & Mary Annual Tax Conference

No abstract provided.


The Post-Tarp Movement To Regulate Banker Pay, Eric D. Chason Jan 2011

The Post-Tarp Movement To Regulate Banker Pay, Eric D. Chason

Faculty Publications

No abstract provided.


Washington Tax Legislative Update: Weathering The Gathering Storm, Jonathan Talisman Nov 2009

Washington Tax Legislative Update: Weathering The Gathering Storm, Jonathan Talisman

William & Mary Annual Tax Conference

No abstract provided.


Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason Jan 2008

Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason

Faculty Publications

No abstract provided.


Creative Structures For The Disposition Of Real Estate (Slides) Nov 2007

Creative Structures For The Disposition Of Real Estate (Slides)

William & Mary Annual Tax Conference

No abstract provided.


Creative Structures For The Disposition Of Real Estate: Extracting Equity On A Tax-Free Basis, Blake D. Rubin, Andrea M. Whiteway, Jon G. Finkelstein Nov 2007

Creative Structures For The Disposition Of Real Estate: Extracting Equity On A Tax-Free Basis, Blake D. Rubin, Andrea M. Whiteway, Jon G. Finkelstein

William & Mary Annual Tax Conference

No abstract provided.


Naked And Covered In Monte Carlo: A Reappraisal Of Option Taxation, Eric D. Chason Jul 2007

Naked And Covered In Monte Carlo: A Reappraisal Of Option Taxation, Eric D. Chason

Faculty Publications

The market for equity options and related derivatives is staggering, covering trillions of dollars worth of assets. As a result, the taxation of these instruments is inherently important. Moreover, the importance is made even more acute by the use of options in creating more complex transactions and in avoiding taxes. Consider an equity call option, which entitles, but does not obligate, its holder to buy stock at a set price at a set time in the future. Option theory gives us a way to break the option down into more fundamental units. For example, an equity call option over 10,000 …


Why Pension Funding Matters, Eric D. Chason Jan 2007

Why Pension Funding Matters, Eric D. Chason

Faculty Publications

No abstract provided.


Disposing Of Overleveraged Real Estate: Thinking Outside The Box, Blake D. Rubin Nov 2005

Disposing Of Overleveraged Real Estate: Thinking Outside The Box, Blake D. Rubin

William & Mary Annual Tax Conference

No abstract provided.


Disposing Of Overleveraged Real Estate: Thinking Outside The Box, Blake D. Rubin, Andrea Macintosh Whiteway Nov 2005

Disposing Of Overleveraged Real Estate: Thinking Outside The Box, Blake D. Rubin, Andrea Macintosh Whiteway

William & Mary Annual Tax Conference

No abstract provided.


Preserving Capital Gains In Real Estate Transactions, Stanley L. Blend, Richard M. Lipton Nov 2005

Preserving Capital Gains In Real Estate Transactions, Stanley L. Blend, Richard M. Lipton

William & Mary Annual Tax Conference

No abstract provided.


Tax Planning For Troubled Real Estate - Focus On The Solvent Taxpayer, Susan T. Edlavitch Nov 2005

Tax Planning For Troubled Real Estate - Focus On The Solvent Taxpayer, Susan T. Edlavitch

William & Mary Annual Tax Conference

No abstract provided.


Planning To Pay Estate Taxes, Louis A. Mezzullo Nov 2005

Planning To Pay Estate Taxes, Louis A. Mezzullo

William & Mary Annual Tax Conference

No abstract provided.