Young-Eun Choi

Mar 12, 2024 | news.bloombergtax.com | Ethan Kroll |John BettAidan Barlow |Young-Eun Choi

It isn’t clear how §267A applies in a Pillar Two world, and Treasury and the IRS may want to think twice about incorporating Pillar Two into §267A, say Baker McKenzie practitioners. The Pillar Two rules combine the income and loss of all related entities that are located in the same jurisdiction for purposes of determining whether any Pillar Two top-up tax is owed for that jurisdiction.

Sep 3, 2023 | globalcompliancenews.com | Young-Eun Choi |Reza Nader |Taylor Reid |Marharyta Bahno

On 25 August 2023, the United States Treasury Department issued a notice of proposed rulemaking regarding tax reporting by brokers of transactions involving the sale or exchange of digital assets (“Proposed Regulations”). These long-awaited Proposed Regulations are in response to section 80603 of the Infrastructure Investment and Jobs Act of 2021, which expanded the scope of information reporting obligations for brokers under Code section 6045 to cover transfers of digital assets.

Sep 1, 2023 | blockchain.bakermckenzie.com | Reza Nader |Taylor Reid |Young-Eun Choi |Marharyta Bahno

On August 25, 2023, the United States Treasury Department issued a notice of proposed rulemaking regarding tax reporting by brokers of transactions involving the sale or exchange of digital assets (“Proposed Regulations“). These long-awaited Proposed Regulations are in response to section 80603 of the Infrastructure Investment and Jobs Act of 2021, which expanded the scope of information reporting obligations for brokers under Code section 6045 to cover transfers of digital assets.

Jun 23, 2023 | bmjopen.bmj.com | Yujin Choi |Sunyoung Choi |Yunna Kim |Young-Eun Choi

Background and rationalePost-traumatic stress disorder (PTSD) is a disorder that occurs after exposure to traumatic events such as death, serious injury or sexual violence.