Jeremy Naylor

Jeremy Naylor is a partner in the Tax Department and a member of the Private Funds Group. Jeremy works with private investment fund sponsors and their investors in all tax aspects of structuring venture capital, private equity, real estate and hedge funds. He also advises U.S. and non-U.S. institutional investors, governmental investors, pension trusts and other tax-exempt organizations in their investments in private funds and joint ventures. In addition, Jeremy works with his fund sponsor clients in designing and implementing carried interest plans and other compensation arrangements for the general partners of private funds.

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Congress and the IRS Make Moves to Improve Taxpayer Compliance for Cryptocurrency Transactions

IRS Commissioner Charles Rettig, testifying before Congress in April 2021, estimated the gap between taxes owed and taxes collected in the United States to be close to $1 trillion. While there is some debate as to how much lax reporting on cryptocurrency transactions contributes to this so-called “tax gap,” with a market capitalization hovering at … Continue Reading

IRS Issues New Guidance for Virtual Currency Donations

By Brianna Reed and Jeremy Naylor on January 30, 2020 Posted in Cryptocurrencies, IRS, Tax

The U.S. Internal Revenue Service (IRS) quietly added two new questions and answers regarding virtual currency donations to its answers to Frequently Asked Questions on Virtual Currency Transactions (FAQs) on December 26, 2019. The two new answers address the responsibilities of charitable organizations when accepting donations of virtual currency, including cryptocurrency. The original FAQs, issued … Continue Reading

IRS Officials Discuss Promotional Airdrops, Pre-2018 Crypto-for-Crypto Exchanges, and Other Issues Not Addressed in Recent Tax Guidance

By Jeremy Naylor and Kathleen R Semanski on December 11, 2019 Posted in Cryptocurrencies, FinCEN, IRS, Tax

In October of 2019, the U.S. Internal Revenue Service issued the first new guidance on the taxation of cryptocurrency transactions in over five years (the “Guidance”). The Guidance comprising a revenue ruling (Rev. Rul. 2019-24) and answers to frequently asked questions on the taxation of cryptocurrency transactions published on the IRS’s website. This post discusses … Continue Reading

IRS Answers Some, but Not All, Questions in Long-awaited Cryptocurrency Guidance

By Jeremy Naylor, Kathleen R Semanski and Michael Fernhoff on October 18, 2019 Posted in Cryptocurrencies, IRS, Tax

The first official guidance on the taxation of cryptocurrency transactions in more than five years has been issued. The guidance includes both a Revenue Ruling (Rev. Rul. 2019-24, 2019-44 I.R.B. 1) and answers to Frequently Asked Questions on Virtual Currency Transactions (the “FAQs,” together with Revenue Ruling 2019-24, the “Guidance”) was issued on October 9, 2019 by … Continue Reading