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Daniel Luchsinger

Dan Luchsinger chairs the firm's Tax Practice Group. He practices in a broad range of federal income tax issues, including the structuring of partnerships and joint ventures; domestic and cross-border acquisitions and dispositions, including both inbound and outbound property and stock transfers; and cross-border restructurings seeking sustainable tax attribute utilization and effective tax rate minimization. Dan regularly oversees multijurisdictional acquisitions and restructurings, drawing on a network of advisors of the highest caliber from around the world.

Dan advises both U.S. and Non-U.S. clients in a number of industries ranging from consumer products to heavy manufacturing, including companies operating through tax advantaged vehicles. For almost a decade, Dan taught Taxation of Partnerships at the Georgetown University Law Center and speaks regularly on a variety of federal income tax topics.

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Last July, the IRS announced its Virtual Currency Compliance Campaign, designed to intensify the IRS’s efforts to counter the underreporting of income related to cryptocurrency use. Through the campaign, the IRS will address noncompliance through taxpayer education, increased audits and initiations of criminal investigations.

This past week the IRS began sending “educational” letters to more than 10,000 taxpayers who either potentially failed to report income and pay the tax from cryptocurrency transactions, or did not report their transactions properly. The IRS sent out three variations of the letters — Letter 6173, Letter 6174, or Letter 6174-A — depending on the severity of the perceived violation. Letters 6174 and 6174-A ask taxpayers to review their returns and file an amended return if necessary; Letter 6173 is a more serious warning that also requires a signature under perjury from the taxpayer affirming U.S. tax law compliance.Continue Reading IRS Ramps Up Efforts to Target Taxpayers Who Deal in Cryptocurrency