Interested if anyone can list some of the practical issues they are having implementing the new section 987 regulations?
Does anyone know the IRS's current practice in terms of returning section 355 private letter rulings? In other words, are people generally getting them within 4 months of filing the request or is it taking longer?
Does virtual currency fall within the definition of marketable securities" under Section 731(c)? What if the virtual currency is actively traded?