On July 30, President Trump’s Working Group on Digital Assets released its comprehensive “Strengthening American Leadership in Digital Financial Technology” report (the Report). The 160-plus-page report sets forth a series of recommendations seeking to “ensure crypto becomes a hallmark of the new American Golden Age” while outlining a proposed framework for regulating digital assets. A key section of the Report focuses on the taxation of digital assets and sets forth proposals on the modernization of the tax framework to better align with the realities of the digital asset ecosystem. The proposals address a range of substantive tax issues, including the classification of digital assets for tax purposes, the timing and character of income from mining and staking activities, and the tax treatment of stablecoins, and also recommends updates to taxpayer and third-party reporting requirements.

Last year in September, we published an alert about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) final rule, which would have imposed certain anti-money laundering and combating the financing of terrorism (AML/CFT) program and other Bank Secrecy Act-related obligations on investment advisers (IA AML Rule) effective January 1, 2026.

In December 2024, Winston’s CTA Task Force attorneys began covering a series of judicial actions that affected the enforcement status of the Corporate Transparency Act and its beneficial ownership information reporting rule.
On December 23, 2023, New York Governor Kathy Hochul signed the LLC Transparency Act into law, with a chapter amendment to be approved by the New York State Legislature. The chapter amendment was later approved, and on March 1, 2024, Governor Hochul signed the amended LLC Transparency Act (the Act) into law. The Act takes effect on January 1, 2026 and requires all limited liability companies formed in New York State or qualified to do business in New York State to file a beneficial ownership disclosure or attestation of exemption with the New York Department of State.