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On April 9, 2021, the Internal Revenue Service (“IRS”) issued a summons, pursuant to a court order, demanding that Circle Internet Financial, LLC f/k/a Circle Internet Financial, Inc. (“Circle”) and affiliates, produce records relating only to U.S. taxpayers that engaged in the trading of digital assets with at least $20K in value of transactions in any one year between 2016 through 2020. Notice of the court order authorizing service of the summons on Circle which the Department of Justice made public on or about April 1, 2021, can be found here. We are writing to inform you that we are complying with this summons which requires us to produce information specific to your account.
If you have any concerns about this, we encourage you to seek legal advice from an attorney.
We also want to highlight that because the IRS served the summons to Circle on April 9, 2021, and our response to the summons has not been fully resolved after more than six months, it is our understanding that the periods of limitations under 26 U.S.C. §§ 6501 (relating to assessment and collection) and 6531 (relating to criminal prosecution) were suspended as of October 9, 2021, and will continue until Circle’s response to the summons is fully resolved. This may be relevant to the tax returns that you have filed for the 2016, 2017, 2018, 2019, and 2020 calendar years. If you have questions about your tax liability for those years, we encourage you to consult with your tax advisor.
Regards,
Team Circle
On April 9, 2021, the Internal Revenue Service (“IRS”) issued a summons, pursuant to a court order, demanding that Circle Internet Financial, LLC f/k/a Circle Internet Financial, Inc. (“Circle”) and affiliates, produce records relating only to U.S. taxpayers that engaged in the trading of digital assets with at least $20K in value of transactions in any one year between 2016 through 2020. Notice of the court order authorizing service of the summons on Circle which the Department of Justice made public on or about April 1, 2021, can be found here. We are writing to inform you that we are complying with this summons which requires us to produce information specific to your account.
If you have any concerns about this, we encourage you to seek legal advice from an attorney.
We also want to highlight that because the IRS served the summons to Circle on April 9, 2021, and our response to the summons has not been fully resolved after more than six months, it is our understanding that the periods of limitations under 26 U.S.C. §§ 6501 (relating to assessment and collection) and 6531 (relating to criminal prosecution) were suspended as of October 9, 2021, and will continue until Circle’s response to the summons is fully resolved. This may be relevant to the tax returns that you have filed for the 2016, 2017, 2018, 2019, and 2020 calendar years. If you have questions about your tax liability for those years, we encourage you to consult with your tax advisor.
Regards,
Team Circle
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