Program Details
2026-10-28 12:00:00
Over 1,000+ webinars
Course Overview
2026-10-28 12:00:00
2h CLE Credits
Intermediate
2
12:00 pm - 1:00 pm ESTThis session explains the reporting regime that will give the IRS standardized third-party basis information for cryptocurrency for the first time: the phased rollout of Form 1099-DA, from gross-proceeds reporting for 2025 sales to mandatory basis and acquisition-information reporting for 2026 sales of covered digital assets, and why pre-2026 or transferred-in cryptocurrency generally remains noncovered. Participants will examine the wallet-by-wallet basis rules of Treas. Reg. § 1.1012-1(j), the Rev. Proc. 2024-28 safe harbor, FIFO and specific identification, and the temporary reporting exceptions for staking, lending, and DeFi transactions. The session closes by placing Form 1099-DA within the IRS’s broader enforcement toolkit — John Doe summonses, blockchain analytics, Letter 6173, and the Ahlgren prosecution — and identifying the taxpayers most likely to face matching problems and examinations as basis reporting comes online.
Evan J. DavisPhilipp Behrendt 1:10 pm - 2:10 pm ESTThe second session turns the new regime into a controversy strategy. Participants will learn how to reconstruct and substantiate basis when the broker reports none, using exchange records, wallet histories, blockchain data, and reconciliation software; how to choose among amended returns, the IRS Voluntary Disclosure Practice and Form 14457, or defending the filed return in light of willfulness, penalties, and limitations periods; and how to manage the IRS contact itself — CP2000 notices, Letter 6173, IDRs, summonses, Kovel arrangements, and privilege. The session closes with the eggshell audit: recognizing badges of fraud and criminal exposure under §§ 7201, 7206, and 7212 early enough to manage the examination accordingly.
Evan J. DavisPhilipp BehrendtEvan J. Davis is a Principal at Hochman Salkin Toscher Perez P.C., where he represents cryptocurrency clients worldwide in civil and criminal tax matters and handles criminal tax investigations and prosecutions, civil tax controversies and complex examinations, Bank Secrecy Act matters, and unreported foreign account issues. Before joining the firm in 2016, he spent nearly two decades in federal government service, including as a civil trial attorney in the Department of Justice Tax Division and as an Assistant United States Attorney in the Central District of California, where he served in the Tax Division and the Major Frauds Section.
Philipp Behrendt is a Principal at Hochman Salkin Toscher Perez P.C., where he advises clients on civil and criminal tax controversies and specializes in the technical aspects of voluntary disclosures in connection with DeFi, NFTs, and other crypto assets. Admitted in both California and Germany, he counsels U.S. and international clients in global tax settings, cross-border investigations, and international money laundering investigations arising from tax avoidance structures.
Evan J. Davis is a Principal at Hochman Salkin Toscher Perez P.C., where he represents cryptocurrency clients worldwide in civil and criminal tax matters and handles criminal tax investigations and prosecutions, civil tax controversies and complex examinations, Bank Secrecy Act matters, and unreported foreign account issues. Before joining the firm in 2016, he spent nearly two decades in federal government service, including as a civil trial attorney in the Department of Justice Tax Division and as an Assistant United States Attorney in the Central District of California, where he served in the Tax Division and the Major Frauds Section.
Philipp Behrendt is a Principal at Hochman Salkin Toscher Perez P.C., where he advises clients on civil and criminal tax controversies and specializes in the technical aspects of voluntary disclosures in connection with DeFi, NFTs, and other crypto assets. Admitted in both California and Germany, he counsels U.S. and international clients in global tax settings, cross-border investigations, and international money laundering investigations arising from tax avoidance structures.
Requirements
The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.
Formats
