IRS & California Tax Blog

Crypto FBAR: Reporting Cryptocurrency on Foreign Exchanges
Kugelman Law

The crypto FBAR question has a surprising answer for 2026: an account that holds only cryptocurrency on a foreign exchange is not currently reportable on the FBAR, but most real-world accounts are not crypto-only, and those usually are reportable. If your foreign exchange account also holds any regular currency or other financial assets, the whole…

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Got Letter 6174 but Never Reported Prior-Year Crypto? How to Amend
Kugelman Law

Quick answer: If you received Letter 6174 and you never reported crypto taxes from earlier years, you can almost always come back into compliance, and in many cases amending your returns is the right way to do it. But amending is not automatically the correct move. The single question that decides your path is whether…

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Delinquent International Information Returns: Fixing Late Forms 5471, 3520, and 8865
Kugelman Law

Quick answer: If you missed delinquent international information returns such as Forms 5471, 3520, 3520-A, 8865, or 8938, you can usually file them late with a reasonable cause statement. If you also failed to report foreign income, a different program is generally the better fit. The penalties start at $10,000 per form, so the order…

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Crypto Voluntary Disclosure: Should You Amend, Disclose, or Wait?
Kugelman Law

If you have unreported cryptocurrency income from past years, crypto voluntary disclosure is the set of paths for coming back into compliance before the IRS finds you first. There are really three choices: amend your returns, enter a formal IRS program, or wait. The right one depends almost entirely on a single question, whether your…

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What the IRS Knows About Your Coinbase History When You Get Letter 6174
Kugelman Law

Quick answer: Does Coinbase report to the IRS? Yes, and by the time a Letter 6174 lands in your mailbox, the IRS very likely already holds data about your exchange activity going back years. It gathers that information from tax forms the exchanges file, from court-ordered summonses that pulled historical account records, and now from…

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Streamlined vs. IRS Voluntary Disclosure: Which Path Fits Your Case
Kugelman Law

The choice between the streamlined procedures and the IRS Voluntary Disclosure Practice comes down to one question: was your failure to report foreign accounts non-willful or willful? Non-willful taxpayers generally use the streamlined program, which is cheaper and simpler. Taxpayers whose conduct may have been willful, and who therefore face potential criminal exposure, generally need…

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QSBS Stacking, Gifting, and the Section 1045 Rollover
Kugelman Law

QSBS stacking is how sophisticated founders and investors try to push the Qualified Small Business Stock benefit beyond a single exclusion cap. The exclusion under Section 1202 is limited per company, but that limit applies separately to each taxpayer who owns the stock. By spreading QSBS among family members or trusts before a sale, and…

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Crypto Scam Loss: Can You Amend to Claim a Theft Loss?
Kugelman Law

Quick answer: If you lost cryptocurrency to a scam and never claimed a crypto scam theft loss on the year it happened, you may be able to amend that return to claim it, and the deduction can be substantial. The rules are technical, and two points decide a lot: scam losses tied to an investment…

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Streamlined Filing Compliance Procedures: Who Qualifies and How They Work
Kugelman Law

The Streamlined Filing Compliance Procedures are the IRS’s main path back into compliance for taxpayers whose failure to report foreign accounts and income was non-willful. In exchange for filing three years of tax returns, six years of FBARs, and a certification that your conduct was non-willful, you resolve the back years at a reduced penalty:…

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Sold Crypto at a Loss? You Probably Still Had to Report It
Kugelman Law

Quick answer: One of the most common crypto tax mistakes is assuming that if you sold at a loss, you did not have to report it. You almost certainly did. Selling or exchanging cryptocurrency is a reportable event whether you made money or lost it, and leaving a loss off your return is exactly the…

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