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Sean McElroy on Muck Rack

Sean McElroy

Michigan
As seen in: Autoline, Medium, Forbes, Lexington Herald-Leader, Bloomberg Law, JD Supra, Cato Institute, Mondaq, Bloomberg Tax, CUInsight.com, yanksarecoming.com
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Articles

Tax Court’s Crypto Staker Ruling Doesn’t Say Much About Staking Original

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By Sean McElroy, Matthew Dimon
| Bloomberg Tax Verified
Last month, the US Tax Court released a memorandum decision in Paschall v. Commissioner. Although some have vastly overstated the holdings of the case, Paschall is both extremely narrow and nonprecedential. For one thing, Paschall is a pro se case. It was decided without a trial or expert testimony, on stipulated facts that fundamentally misstate how staking works. Included in the parties’ stipulated facts were that Paschall “received” certain staking rewards from the eToro platform.
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Paschall: Tax Court Memorandum Holds that Staking Rewards are Taxable Income in Pro Se Case on Erroneous Stipulated Facts

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By David Forst, Sean McElroy
| fenwick.com
On June 4, 2026, the U.S. Tax Court released a memorandum decision in Paschall v. Commissioner addressing the federal tax treatment of staking, holding that there was taxation on staking rewards credited to Mr. Paschall’s eToro account. The decision is non-precedential, it was argued by the taxpayer pro se, and it was decided on sloppy and incorrect stipulated facts.
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IRS Reinstates ‘Significant Issue’ Letter Rulings for § 355 Spin‑Offs and Reorganizations

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By Sean McElroy, William B. Skinner
| JD Supra
IRS Rev. Proc. 2026-21, 2026-22 IRB 1, issued May 5, 2026, reinstates the Internal Revenue Service’s “significant issue” letter ruling program, under which the IRS will rule on specific, significant issues posed by a transaction without ruling on the entire integrated transaction. This new ruling program comes after the IRS suspended it in 2024, and after the agency withdrew proposed regulations on tax-free spin-offs last September.
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