Overview
On November 23, 2022, Tax Notes quoted Lisa Zarlenga in a piece titled "Time for Some Creative Thinking About Crypto Tax Compliance." The article discusses options for cleaning up taxpayers’ noncompliance the voluntary disclosure program applies only to willful noncompliance, though a qualified amended return can apply to nonwillful noncompliance. The article also discusses expanding the private letter ruling practice for more certainty.
Zarlenga expressed that the IRS uses ruling requests to acquire an understanding of what transactions taxpayers are engaging in. She noted, "The biggest difficulty in increasing letter ruling practice in a way that could help both the government and taxpayers could be the IRS finding enough employees to analyze those requests."
The full article can be read at Tax Notes.
