El IIVTNU ha recibido y sigue recibiendo muchas críticas por su concurrencia con los distintos tributos que gravan las plusvalías, así como por el actual sistema de cálculo de las citadas plusvalías, que lo aleja del principio de capacidad económica. Muchos autores han propuesto su...

This report argues that including proof-of-stake cryptocurrency block rewards in gross income when the reward tokens are first created results in inequitable taxation and would discourage U.S. taxpayers from participating in this new technology. The better approach is to tax reward tokens when...

Blockchain technology, perhaps the most revolutionary invention of the 21st century, was popularized by introducing the world's first cryptocurrency 'Bitcoin.' However, despite many purported advantages offered by cryptocurrencies, they eluded mass adoption due to their extreme volatility. This...

Spanish Abstract: El gran incremento de impuestos autonómicos que existe hoy, así como la gran cantidad de resoluciones judiciales del Tribunal Constitucional, de reciente aparición, hace necesario dedicar un estudio al análisis crítico del art. 6 de la LOFCA, especialmente después de la...

• An unsettled issue of immense practical and economic importance: how to tax the new “reward tokens” created in public cryptocurrency networks.• The wrong policy would drive innovation elsewhere. Fortunately, the correct policy is mandated by existing law: these new tokens – like all...

New cryptocurrency staking "reward" tokens are not and should not be taxable when they are created. This article presents the basic economics of cryptocurrency staking and the applicable income tax law. It responds to counterarguments from the New York State Bar Association's Tax Section and...

Brief in support of Joshua Jarrett’s petition to the IRS seeking to establish that his cryptocurrency “staking rewards” are not taxable income until sold. Upon the IRS’s failure to respond to or rule on this petition, suit was filed in Joshua Jarrett v. United States, No. 3:21-cv-00419...

With recent accessions to the federal-provincial Harmonized Sales Tax, provinces with value added taxes (VATs) now comprise over two-thirds of the national economy. While Canadian VATs are economically superior to the taxes they replaced, they are not as well designed as in other countries. An...

The economic downturn has created an investment market in which some tax-advantaged strategies have become favored. To avoid taxable diversification, taxpayers have turned to exchange funds. Through the rules in sections 351, 721, and 368, taxpayers can diversify a single stock position without...

In early 1924, James Couzens was a Republican Senator from Michigan and reportedly the richest member of Congress. Andrew Mellon was beginning his fourth year as Secretary of the Treasury — a service that would eventually span 11 years under three Republican Administrations — and one of the...