Kathleen R Semanski

Kathleen R. Semanski is an associate in the Tax Department.

Firm/Organization: Proskauer Rose LLP

Blogs: Blockchain and the Law, New Media and Technology Law Blog, Not For Profit/Exempt Organizations Blog, Tax Talks

Latest Articles

Blockchain and the Law

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

By Jeremy Naylor & Kathleen R Semanski

December 11, 2019

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 recent news reports of statements by officials with the IRS and the Treasury Department’s Financial Crimes Enforcement Network…

Blockchain and the Law

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

By Michael Fernhoff, Jeremy Naylor & Kathleen R Semanski

October 18, 2019

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 the U.S. Internal Revenue Service (the “IRS”). The Guidance provides much sought information concerning the tax…

Tax Talks

IRS answers some, but not all, questions in long-awaited cryptocurrency guidance

By Michael Fernhoff, Jeremy Naylor & Kathleen R Semanski

October 17, 2019

Tax Talks

Impact of Proposed Regulations under Section 956 on Lending Arrangements Involving U.S. Corporate Borrowers

By Martin T. Hamilton, Annie Kim, David S. Miller, Xiaoyang Ma & Kathleen R Semanski

November 13, 2018

Introduction On October 31, 2018, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) proposed new regulations (the “Proposed Regulations”)[1] that are likely to allow many controlled foreign corporations (“CFCs”)[2] of U.S. multi-national borrowers to guarantee the debt of their parents and to allow the U.S. parent to pledge more than 66 2/3% of the voting stock of the CFC (and to have the CFC provide negative covenants),…

Tax Talks

Impact of Recent Tax Legislation on M&A Transactions

By Alan Parnes, Amanda H. Nussbaum, Abraham Gutwein, Martin T. Hamilton, Richard M. Corn, Malcolm Hochenberg, Amy Zelcer, Martine Seiden Agatston & Kathleen R Semanski

February 9, 2018

This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in cross-border transactions, and this post describes them in general terms without all of their fine details. The discussion of foreign corporations below is in the context of foreign subsidiaries of U.S. groups. Multiple Lower Effective Corporate Tax Rates…

Tax Talks

House of Representatives and Senate Conferees Reach Agreement on the Tax Cuts and Jobs Act (H.R. 1): Description of the Conference Agreement and Differences from House and Senate Versions

By David S. Miller, Richard M. Corn, Steven Einhorn, Martin T. Hamilton & Kathleen R Semanski

December 18, 2017

On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1) (the “Final Bill”), and released legislative text, an explanation, and the Joint Committee on Taxation estimated budget effects (commonly referred to as the “score”). Next week the House and Senate are each expected to pass the bill, and it is expected to be sent to the President for signature the following week. …

Tax Talks

U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and Outstanding Differences to be Resolved in Conference

By David S. Miller, Richard M. Corn, Steven Einhorn, Martin T. Hamilton & Kathleen R Semanski

December 8, 2017

In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation (the “House bill”). Members of the House and Senate will next convene in conference to attempt to reconcile the House and Senate versions of the legislation. Identical versions of the bill must be passed by…

Tax Talks

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

By Kathleen R Semanski

December 6, 2017

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of cryptocurrency transactions. The following is a very high-level discussion of the consequences generally applicable to U.S. individual holders of cryptocurrencies, and will not be applicable to all taxpayers depending on their particular situation. Is it property or is it…

New Media and Technology Law Blog

U.S. Court Orders Coinbase to Share Information about Account Holders with the IRS but Limits to Transactions over $20,000

By Kathleen R Semanski

December 1, 2017

A U.S. federal district court judge on Tuesday, November 29 ordered Coinbase Inc., the largest cryptocurrency exchange and storage platform in the world, to provide information about certain of its account holders to the U.S. Internal Revenue Services (IRS). Information pertaining to as many as 14,355 account holders and 8.9 million transactions could be covered in this order, according to estimates provided by Coinbase. The full order by Judge Jacqueline Scott Corley of the U.S.…

Blockchain and the Law

U.S. Court Orders Coinbase to Share Information about Account Holders with the IRS but Limits to Transactions over $20,000

By Kathleen R Semanski

December 1, 2017

Kathleen R Semanski

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

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

IRS answers some, but not all, questions in long-awaited cryptocurrency guidance

Impact of Proposed Regulations under Section 956 on Lending Arrangements Involving U.S. Corporate Borrowers

Impact of Recent Tax Legislation on M&A Transactions

House of Representatives and Senate Conferees Reach Agreement on the Tax Cuts and Jobs Act (H.R. 1): Description of the Conference Agreement and Differences from House and Senate Versions

U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and Outstanding Differences to be Resolved in Conference

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

U.S. Court Orders Coinbase to Share Information about Account Holders with the IRS but Limits to Transactions over $20,000

U.S. Court Orders Coinbase to Share Information about Account Holders with the IRS but Limits to Transactions over $20,000

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