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.

For a discussion of this new guidance, please see the post on Proskauer’s Blockchain and the Law blog.

Photo of Jeremy Naylor Jeremy Naylor

Jeremy Naylor is a partner in the Tax Department and a member of the Private Funds Group. Jeremy works with fund sponsors across asset classes, and their investors, in all tax aspects of private investment fund matters.

In addition, Jeremy works with his…

Jeremy Naylor is a partner in the Tax Department and a member of the Private Funds Group. Jeremy works with fund sponsors across asset classes, and their investors, in all tax aspects of private investment fund matters.

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.

Jeremy 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.

He also frequently represents secondary fund managers in connection with the tax aspects of their business, including fund formation, secondary transactions (including restructurings and private tender offers), primary investments and co-investments.

Jeremy also advises on M&A transactions involving his investment management clients, including minority sale transactions, preferred financing and control transactions.

Jeremy has significant experience structuring inbound investment in U.S. real estate by non-U.S. investors. In addition, Jeremy has significant experience in structuring domestic and cross-border mergers and acquisitions, advising on capital markets transactions and equity compensation arrangements.

Jeremy is a frequent speaker at industry conferences related to private investment funds, including the Merrill Lynch Private Equity and Venture Capital CFO Conference and the Practising Law Institute’s series on international tax. In addition, Jeremy frequently participates in webinars and provides other thought leadership in print media related to changes in the tax laws and their impact on private fund managers.

Read more about Jeremy NaylorEmail
Show more Show less
Photo of Brianna Reed Brianna Reed

Brianna Reed is an associate in the firm’s Tax Department and a member of the Private Funds Group.

Her practice focuses on tax planning for domestic and international private investment funds, including venture capital, hedge, secondary, funds-of-funds, and other investment partnerships. Brianna counsels…

Brianna Reed is an associate in the firm’s Tax Department and a member of the Private Funds Group.

Her practice focuses on tax planning for domestic and international private investment funds, including venture capital, hedge, secondary, funds-of-funds, and other investment partnerships. Brianna counsels sponsors on all types of fund-related transactions and operations, including:

  • fund formation and fund-raising;
  • fund structuring and internal organization;
  • carried interest and other compensation arrangements;
  • buy-side secondary transactions and sell-side secondary transactions;
  • fund restructurings; and
  • portfolio company investments.

She also counsels investors regarding various tax considerations as they invest  in private funds and co-investment vehicles. These clients include:

  • institutional investors;
  • non-U.S. entities;
  • tax-exempt organizations;
  • U.S. persons making investments outside of the U.S.; and
  • regulated investment companies.

Brianna’s pro bono work involves advising non-profit organizations on applying for and maintaining federal income tax exemption, and advocating on behalf of victims of domestic violence and abuse. She received Proskauer’s Golden Gavel Award for excellence in pro bono work in 2019.

Brianna serves on the Steering Committee of Proskauer’s Women’s Alliance. She was also one of a few women selected to be a Protégée for Proskauer’s Women Sponsorship Program, an initiative for high performing midlevel lawyers that champions emerging leaders.

Outside of Proskauer, Brianna is a member of the Taxation Law Section Council of the Massachusetts Bar Association, which educates lawyers in areas of tax law and provides leadership in state tax law changes. She was selected as a fellow for the Massachusetts Bar Association’s Leadership Academy Class of 2021-2022. Brianna is also active in volunteer activities involving educational initiatives.

Prior to joining Proskauer, Brianna was an associate at a premier law firm, where she maintained a broad tax practice, including advising on tax aspects of mergers and acquisitions and other complex business transactions. She also previously worked in the tax department of a major U.S. defense contractor.

Read more about Brianna ReedEmail
Show more Show less