Andrew G. Mirisis is a multi-disciplined tax attorney with over a decade of public and private sector experience.
Matthew L. Roberts
Mr. Roberts is a Principal of the firm. He devotes a substantial portion of his legal practice to helping his clients successfully navigate and resolve their federal tax disputes, either administratively, or, if necessary, through litigation.
On-Demand:February 14, 2023
$95.001 hour CLE
Please Select Class Format
Free access to all CLE programs w/active subscription. Annual subscription only $395/yr.
This webinar will cover how investors may be able to claim tax deductions for digital asset or cryptocurrency losses. The webinar will start with a brief introduction on the recent cryptocurrency bankruptcies and some bankruptcy law basics that are relevant to an investor seeking to claim a tax loss. Next, we will cover the basics of capital losses under section 165(f). This will include a discussion of the limitations in sections 1211 and 1212. The program will also cover claiming digital asset or cryptocurrency losses as a section 165(g) worthless stock deduction. Finally, we will discuss the strict requirements for claiming a section 165(e) theft loss related to digital assets or cryptocurrency.
Key topics to be discussed:
Recent cryptocurrency bankruptcies
Bankruptcy law basics that are relevant to an investor seeking to claim a tax loss
Basics of capital losses under section 165(f)
Discussion of the limitations in sections 1211 and 1212
Claiming digital asset or cryptocurrency losses as a section 165(g) worthless stock deduction
Discussion about the strict requirements for claiming a section 165(e) theft loss related to digital assets or cryptocurrency
Date: February 14, 2023
Andrew G. Mirisis | Freeman Law
Andrew G. Mirisis is a multi-disciplined tax attorney with over a decade of public and private sector experience. He relies on that experience to provide advice and counsel his clients and to reach practical and cost-effective solutions.
Mr. Mirisis focuses his practice on domestic and international tax planning and tax litigation. He advises clients on a broad range of domestic and international tax matters including, asset repatriations, acquisitions, dispositions, restructurings, and cross-border transactions. Mr. Mirisis has particular experience advising controlled foreign corporations (CFCs) on the nuances of the section 245A participation exemption, subpart F, and global intangible low-taxed income regimes and their impacts on the CFC’s U.S. shareholders. He also has expertise in the application of U.S. tax treaties to avoid double taxation, analyzing permanent establishment status, and withholding rules for payments made to foreign persons.
Mr. Mirisis’s significant public and private sector experience informs his approach to tax planning and tax litigation and makes him uniquely positioned to resolve his client’s issues. Early in his career Mr. Mirisis served as a law clerk for the United States Bankruptcy Court for the District of Delaware (2011-2012), one of the premier jurisdictions for chapter 11 corporate bankruptcy practice, and for the United States Tax Court in Washington, D.C. (2014-2016), the pre-refund jurisdiction for taxpayers seeking a redetermination of a deficiency determined by the IRS. In his role as a law clerk, Mr. Mirisis analyzed complex procedural and substantive tax issues for taxpayers of all types and sizes. He gained particular experience in the areas of conservation easements, whistleblower award determinations, section 6751 procedural requirements, penalties and collection due process.
In addition to his federal clerkships Mr. Mirisis was an associate attorney for a large international law firm and litigated cases in federal and state courts throughout the country. Prior to joining Freeman Law, Mr. Mirisis was a Senior Manager in the International Tax Services group of the Washington National Tax Services office of PricewaterhouseCoopers LLP where he advised multinational corporations on a broad range of international tax issues.
Matthew L. Roberts | Freeman Law
Mr. Roberts is a Principal of the firm. He devotes a substantial portion of his legal practice to helping his clients successfully navigate and resolve their federal tax disputes, either administratively, or, if necessary, through litigation. As a trusted advisor he has provided legal advice and counsel to hundreds of clients, including individuals and entrepreneurs, non-profits, trusts and estates, partnerships, and corporations.
Having served nearly three years as an attorney-advisor to the Chief Judge of the United States Tax Court in Washington, D.C., Mr. Roberts leverages his unique insight into government processes to offer his clients creative, innovative, and cost-effective solutions to their tax problems. Professionally licensed as an attorney for more than a decade, Mr. Roberts has successfully represented clients in all phases of a federal tax dispute, including IRS audits, appeals, litigation, and collection matters. He also has significant experience representing clients in employment tax audits, voluntary disclosures, FBAR penalties and litigation, trust fund recovery penalties, penalty abatement and waiver requests, and criminal tax matters.
Often times, Mr. Roberts has been engaged to utilize his extensive knowledge of tax controversy matters to assist clients in their transactional matters. For example, he has provided tax advice to businesses on complex tax matters related to domestic and international transactions, formations, acquisitions, dispositions, mergers, spin-offs, liquidations, and partnership divisions.
In addition to federal tax disputes, Mr. Roberts has represented clients in matters relating to white-collar crimes, estate and probate disputes, fiduciary disputes, complex contractual and settlement disputes, business disparagement and defamation claims, and other complex civil litigation matters including allegations of fraud.
Mr. Roberts received his Bachelor of Accountancy and his Master of Science in Taxation from the University of Mississippi. He received his law degree, summa cum laude, from the University of Mississippi School of Law, where he graduated in the top five percent of his law school class. During law school, he was an editor for the Mississippi Law Journal and also an executive board member of the Moot Court Board.
After law school, he received an LL.M. (Master of Laws) in Taxation from New York University School of Law. He is a frequent speaker and author on complex tax matters, and his articles have been published in national and regional publications including the Journal of Practice and Procedure, Tax Notes, The Tax Advisor, and Today’s CPA.
Mr. Roberts has also served as a tax law professor at the Southern Methodist University Dedman School of Law, where he taught Corporate Income Taxation.
I. Recent cryptocurrency bankruptcies | 2:00pm – 2:10pm
II. Bankruptcy law basics that are relevant to an investor seeking to claim a tax loss | 2:10pm – 2:20pm
III. Basics of capital losses under section 165(f) | 2:20pm – 2:30pm
IV. Discussion of the limitations in sections 1211 and 1212 | 2:30pm – 2:40pm
V. Claiming digital asset or cryptocurrency losses as a section 165(g) worthless stock deduction | 2:40pm – 2:50pm
VI. Discussion about the strict requirements for claiming a section 165(e) theft loss related to digital assets or cryptocurrency | 2:50pm – 3:00pm