Thought Leadership
Books
- Federal Taxation of Software and Digital Transactions
- BNA Tax Management Portfolio No. 555-2nd (2020)
- Taxation of E-Commerce
- Internet Law for the Business Lawyer (American Bar Association, 2001)
Articles
- Crypto regulations proposed by U.S. Treasury
- Baker McKenzie InsightPlus (August 31, 2023)
On 25 August 2023, the United States Treasury Department issued a notice of proposed rulemaking regarding tax reporting under Section 6045 of the Internal Revenue Code by brokers of transactions involving the sale or exchange of digital assets. - IRS issues guidance on staking
- Baker McKenzie InsightPlus (August 16, 2023)
In Revenue Ruling 2023-14, issued 31 July 2023, the IRS ruled that a cash-method taxpayer that receives additional units of cryptocurrency as rewards for validating transactions on a proof-of-stake blockchain must recognize the fair market value of the validation rewards as income in the taxable year in which the taxpayer gains dominion and control over the validation rewards. - U.S. Senate shows interest in crypto taxation
- Baker McKenzie InsightPlus (July 20, 2023)
The United States Senate solicited input from the public on the appropriate treatment of digital assets under US federal income tax law. - HMRC takes positive steps on DeFi
- Baker McKenzie InsightPlus (May 11, 2023)
HMRC releases a second consultation regarding the taxation of DeFi lending transactions. - Crypto tax proposals in the 2024 Greenbook
- Baker McKenzie InsightPlus (March 14, 2023)
Biden administration tax proposals for fiscal year 2024 related to cryptocurrency and other digital assets. - GILTI, FDII, and the Future of International IP Planning
- TAXES—The Tax Magazine, May 2018, at 5
This column addresses Code Sec. 951A, the new category of income under subpart F for “global intangible low-taxed income” or “GILTI,” and new Code Sec. 250, the deduction for GILTI and “foreign-derived intangible income” or “FDII,” in the context of a typical international structure for a U.S.-based multinational enterprise. - A Break in the Clouds: A Proposed Framework for Analyzing Cloud Computing Transactions
- TAXES—The Tax Magazine, Mar. 2014, at 31
Cloud computing has emerged as an effective way to provide users with access to shared computing resources. This article examines the application of income characterization and source of income rules to typical remote access transactions. - Foreign Tax Credit Splitters: Temporary and Final Regulations
- Journal of International Taxation, Jun. 2012, at 44
- United States Taxation of Income Derived from International Electronic Commerce Transactions
- 41 Tax Management Memorandum 503 (Dec. 4, 2000)
- OECD Characterization TAG Deliberations: A Push for Consensus
- 1 BNA E-Commerce Tax Report 432 (Oct. 30, 2000)
- Tax Characterization of Electronic Commerce Revenue
- 1 BNA E-Commerce Tax Report 197 (Jul. 10, 2000)
Presentations
- What is Not in the First Final §6045 Regulations?
- SJSU Blockchain Tax Conference (January 24, 2025)
Moderated a panel discussion on the recently promulgated DeFi broker tax reporting regulations and the interplay with the Crypto Assets Reporting Framework (CARF).
- Crypto Developments
- 52nd Annual Conference of the USA Branch of the International Fiscal Association (March 21, 2024)
Panel exploring the federal income tax implications surrounding digital assets, specifically, digital asset reporting, staking, cryptocurrency lending, including safe harbor rules with respect to cryptocurrency trading.
- Crypto Taxation
- Blockchain, Digital Assets and the Law (2023 and 2024)
Guest lecture on the taxation of cryptocurrency assets and blockchains, part of a Master of Laws course on emerging law and regulation surrounding blockchain technology and digital assets at the University of Toronto Faculty of Law.
- DeFi
- Crypto Boot Camp (December 1, 2022)
Webinar on decentralized finance and the interrelationship with financial services regulation and taxation.