A Note from the Editors-in-Chief

In the United States, the House proposed to make changes to the wash sale and constructive sale rules as part of the Build Back Better Act, and the Treasury Department Greenbook proposed to make changes and clarifications to the treatment of cryptocurrency loans, allow mark-to-market accounting for cryptocurrency dealers and traders, and create a new information reporting framework. [...]it includes some discussion that may indicate how the Tax Court would allocate payments on distressed debt instruments between principal and interest-an issue that is important to both borrowers (such as the taxpayers in Howland) and lenders receiving settlement payments on loans subject to the doubtful collectability exception to interest accrual. In addition to its implications on the application of retirement payments, the Tax Court holding is also significant in that it creates a relatively high burden of proof for borrowers that may be difficult to meet in the absence of a lender-issued IRS Form 1098, Mortgage Interest.