Jason B. Freeman's Blog

Just before the turn of the new year, Congress passed—and the president signed—the Tax Cuts and Jobs Act of 2017 (“TCJA”).  The TCJA represents the most extensive rewrite of the U.S. tax code in over 30 years.  The new act contains a number of important provisions that will impact business tax pl...

The IRS recently announced that it will officially close the Offshore Voluntary Disclosure Program (“OVDP”) in September of 2018.  Its announcement serves as a “last call” for taxpayers who have willfully failed to report foreign assets or income—a last opportunity to come forward under the terms...

What are the tax implications of a cryptocurrency Hard Fork?  Does the holder of a cryptocurrency that undergoes a Hard Fork realize taxable income? If so, how does one determine the amount of the income and when, exactly, it is received?  These are not easy questions to answer.What is a Hard For...

Sensitive audits present the tax practitioner with unique challenges.  They require the exercise of judgment and discretion, as well as an understanding of administrative procedure and even a command of constitutional and evidentiary rules.  At times, they may also require that the practitioner c...

We are in the midst of a revolution-a digital transformation driven by what many believe could be the most powerful decentralizing force since the rise of the Internet: Blockchain. It is difficult to overstate the potential impact of this technology and its applications. Much as the double-entry ...