Senior Associate
Norton Rose Fulbright US LLP
Hersh Verma joined Norton Rose Fulbright's Houston office in September 2015. Hersh's practice focuses on advising clients on a wide range of tax matters, with particular emphasis on federal and international taxation planning and structuring and tax controversy matters.
Recent Articles & Comments
The SIFMA letter relies on Revenue Ruling 2019-24 to support its position on the tax treatment of incidental assets. The ruling's principle, that a taxpayer does not have gross income from a hard fork unless they can exercise "dominion and control," is cited as precedent for why the IRS should respect the abandonment of such assets by a Digital Asset ETF. However, SIFMA rightly points out that this guidance is incomplete, as it fails to clarify whether income from airdrops or hard forks…