Downward attribution: How a non-US controlled corporation magically becomes US-controlled

As kids, my siblings and I would play a game called Opposite Day. When you said something, the meaning was intended to be the exact opposite of the words you used. Maybe you enjoyed had a similar game. And generally, it was harmless fun, but the game would grow weary. Likewise, Tax Reform created its own opposite day. Now a foreign-controlled corporation may now considered to be the opposite, as US-controlled foreign corporation, creating a weary game. A very weary game indeed.

The Wash Sale Rule and Cryptocurrency

When you sell a capital asset, the difference between the adjusted basis in the asset and the amount you realized from the sale is a capital gain or a capital loss. Selling a security at a lower price than it was purchased qualifies as a capital loss. That is, however, unless you repurchase the same stock or security within 30 days (well technically 61-day window). These sorts of sales are considered wash sales, and they are excluded from the capital loss deduction allowance. So the question is, does the same rule apply to cryptocurrencies? The answer is most likely not. In this article we will explain our reasons why.

The top ten reasons why FATCA is a complete loser of a law

The Treasury Inspector General for Tax Administration (TIGTA) published a report on July 5,, 2018 regarding the Foreign Account Tax Compliance Act (FATCA). TIGTA’s conclusions do little to dispel the general consensus that FATCA is an awful, dreadful piece of legislation on par with other terrible federal laws like the Volstead Act (Prohibition) and the Fugitive Slave Act. We decided to celebrate this occasion by sharing with you our “Top Ten Reasons why FATCA is a Miserable Failure.”