Nationally Recognized Crypto CPA Since 2016 and the first CPA firm in the U.S. to accept cryptocurrency for professional services.

Tax Notes
Federal & Global
Published Research

Digital Asset Taxation in the United States: A Policy Analysis

Co-authored with the former head of the IRS Office of Digital Assets and co-author of the §6045 digital asset broker reporting regulations. Published in Tax Notes Federal and Tax Notes Global.

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Client Case Studies

The following engagements illustrate how Camuso CPA approaches complex digital asset tax, accounting, and compliance work. All client details are anonymized.

Cost Basis Reconstruction

Case Study

30+ Wallets, 60,000+ Transactions, Defunct Platform Records Reconstructed with Ongoing Portfolio Accounting

Client TypeActive DeFi Investor
Wallets30+
Transactions60,000+

The Problem

An active DeFi investor with over 60,000 transactions across 30+ wallets had unrecoverable records from Celsius and other defunct platforms, data gaps across years of on-chain activity, and no transaction-level tracking, account-level allocation, or Rev. Proc. 2024-28 compliance framework in place.

What We Did

Reconstructed the full history using on-chain data, secondary documentation, and a documented assumptions register for unrecoverable records. Reclassified internal transfers and bridging events, aligned methodology with Rev. Proc. 2024-28, and built lot-level cost basis records across the full portfolio history.

The Outcome

Full history reconstructed including documented positions for unrecoverable records. Cost basis continuity established at the lot level. Ongoing quarterly accounting system in place.

Cost Basis Reconstruction

Case Study

7 Years, 35+ Wallets, Cost Basis Rebuilt from Raw Data After Software Corrupted It

Client TypeActive Multi-Exchange and DeFi Investor
Scope10+ Exchanges, 35+ Wallets, 7 Years
Software HistoryMultiple Consumer Tax Platforms

The Problem

The client's cost basis records had been corrupted by seven years of consumer tax software. Transfers between their own wallets were treated as sales, breaking the basis chain every time an asset moved. Gains appeared on assets never sold, and each platform migration carried old errors forward and added new ones. Returns had been filed from these reports, and there was no reliable basis figure anywhere in the portfolio.

What We Did

We set the software output aside and rebuilt cost basis from exchange records, wallet histories, and on-chain data across the full seven years. We matched internal transfers across more than 35 wallets so basis carried through each move, removed duplicated activity, and established lot-level basis under one consistent, documented methodology, quantifying each difference from what had been filed.

The Outcome

Lot-level cost basis that reconciles to source data across the full portfolio history, one methodology applied across all years, and documentation behind every number. Prior-year differences identified with a clear path to correction, and ongoing tracking keeps the basis chain intact going forward.

Cost Basis Reconstruction

Case Study

8 Unfiled Years, 25+ Wallets, Cost Basis Established from Almost Nothing

Client TypeEarly Crypto Adopter
Unfiled Years8
Scope25+ Wallets, Multiple Defunct Exchanges

The Problem

The client had been in crypto since the early cycles and had never reported the activity. Eight unfiled years was the visible problem. The deeper one was that no cost basis existed at all. No exports had been saved, several early exchanges had shut down taking their records with them, and there was no documentation of what anything originally cost. Without basis, the returns could not be prepared.

What We Did

We reconstructed cost basis from on-chain data across more than 25 wallets and recovered exchange records where recovery was still possible. For records that no longer exist, we built documented basis positions supported by secondary sources and a written assumptions register, then prepared the delinquent returns on a single consistent methodology, sequenced with penalty mitigation in mind.

The Outcome

Cost basis established and documented across all eight years, including positions for records that could not be recovered. All returns filed on that foundation, with the basis chain maintained annually going forward.

Cost Basis Reconstruction

Case Study

10 Years, 40+ Wallets, Lot-Level Cost Basis Established Before an Eight-Figure Disposition

Client TypeHigh-Net-Worth Long-Term Holder
PortfolioEight Figures Across Multiple Cycles
Scope40+ Wallets, 10 Years

The Problem

The client was preparing to sell a significant portion of a portfolio built over ten years, and no cost basis existed to sell against. Holdings had accumulated across a decade of purchases, transfers, and wallet migrations, none of it tracked at the lot level. Without established basis and holding periods there was no way to select lots, manage the size or character of the gain, or support the numbers on the return.

What We Did

We reconstructed lot-level cost basis across more than 40 wallets and ten years of activity before any sale occurred. We aligned the methodology with Rev. Proc. 2024-28 account-level requirements, documented holding periods across the portfolio, and built a disposition plan around the established basis covering lot selection, timing, and gain characterization ahead of the liquidity event.

The Outcome

The disposition was executed on selected lots with documented basis and holding periods, giving the client control over an outcome that would otherwise have defaulted to the least favorable treatment. Lot-level records remain in place for everything still held.

Reconciliation and Wallet Allocation

Case Study

7 Years, 20+ Platforms, $1M+ in Cost Basis Rebuilt Year by Year and Allocated by Wallet After Ten Venues Shut Down

Client TypeLong-Term Individual Investor
Scope2017 to 2024, 20+ Platforms and Wallets
Portfolio~300 Assets, ~3,000 Tax Lots, $1M+ Cost Basis

The Problem

The client had filed every year and believed the reporting was correct, then found the books no longer tied to the portfolio. Positions appeared in the transaction history that existed in no wallet, and balances sat in wallets the data said should be empty. Seven years of small discrepancies had accumulated behind it, including unrecorded platform rewards, assets sold on venues that later shut down, token migrations recorded as disappearances, and dust from defunct projects still carrying basis. At least ten of the platforms where the original purchases occurred no longer exist in usable form. Without accurate year-end balances the client could not compute defensible gain and loss or perform the wallet-by-wallet basis allocation required by the move off the universal method.

What We Did

We rebuilt the transaction history sequentially from 2017 forward, carrying each year's closing balances into the next as the opening position tested against. Working forward is slower than reconciling from a current-year snapshot, and it is the only method that isolates where the books actually broke. What survived the rebuild was a residual set of variances concentrated in assets purchased on venues that no longer exist. Each was sorted into a defined category with a documented accounting treatment, applied conservatively and without claiming deductions the law does not support. Every category, asset, and dollar of tax effect was documented and approved in writing before any entry was booked.

The Outcome

The client holds finalized year-end balances and tax lots, more than $1 million of cost basis allocated wallet by wallet, and a variance resolution record supporting every adjustment. Camuso CPA also prepared amended returns to remediate the prior-year reporting, and now handles the client's annual accounting and tax filings.

Reconstruction and Tax Planning

Case Study

9 Years, 45+ Wallets, Cost Basis Reconstructed and Quarterly Tax Planning Built on Top of It

Client TypeActive High-Volume Investor
Scope45+ Wallets, 9 Years, Heavy DeFi Activity
EngagementReconstruction Plus Quarterly Tax Planning

The Problem

The client had nine years of activity across more than 45 wallets with cost basis records that were fragmentary at best. Beyond the record problem, the client was still trading actively, which meant every disposition happened blind. No lot selection, no view of unrealized positions, no way to harvest losses, and no sense of what the current year's tax bill was building toward until it arrived.

What We Did

We reconstructed lot-level cost basis across the full nine years, matching internal transfers so basis carried through every move, and aligned the methodology with Rev. Proc. 2024-28 requirements. On that foundation we built an ongoing quarterly tax planning engagement covering lot selection on dispositions, loss harvesting, holding period timing, and quarterly projections so the tax picture is visible as it forms.

The Outcome

The client trades on documented lot-level basis with quarterly projections and a planning framework guiding disposition decisions through the year. Camuso CPA manages both the annual reporting and the quarterly planning cycle.

Reconstruction and Tax Planning

Case Study

8 Years, 30+ Wallets, Cost Basis Reconstructed and a Multi-Year Disposition Strategy Built for a Concentrated Position

Client TypeHigh-Net-Worth Investor, Concentrated Holdings
Scope30+ Wallets, 8 Years
EngagementReconstruction Plus Multi-Year Tax Planning

The Problem

The client held a concentrated portfolio built over eight years, with most of the value in a small number of positions accumulated across more than 30 wallets. No lot-level basis existed, and the client's goals had shifted from accumulating to gradually reducing concentration over several years. Without established basis and holding periods, every sale would have been a guess, with no control over gain size, character, or which years absorbed the tax.

What We Did

We reconstructed lot-level cost basis across the full eight years, documented holding periods across every position, and aligned the methodology with Rev. Proc. 2024-28 requirements. On that foundation we built a multi-year disposition strategy, mapping which lots to sell in which years, pacing gains against the client's income picture, harvesting losses where available, and running annual projections so each year's dispositions are planned before they happen.

The Outcome

The client is executing a paced, multi-year reduction of the concentrated position on documented basis, with each year's tax outcome projected and planned in advance. Camuso CPA manages the ongoing planning cycle as prices, income, and goals move.

1099-DA Compliance

Case Study

Multiple 1099-DAs with Legacy Basis, Unreported DEX Activity, and Rev. Proc. 2024-28 Realignment

Client TypeActive Crypto Investor
Forms ReceivedMultiple 1099-DAs Across Exchanges
Key IssuesLegacy Basis, DEX Activity, Methodology Misalignment

The Problem

Client received 1099-DAs with legacy basis brokers could not report, significant DEX activity generating no 1099-DA, and a prior methodology no longer aligned with Rev. Proc. 2024-28 account-level requirements.

What We Did

Reconstructed lot-level cost basis for all legacy assets, transitioned to account-level tracking under Rev. Proc. 2024-28, reconciled all 1099-DA data against rebuilt records, and incorporated all unreported DEX activity into a complete Form 8949 filing.

The Outcome

Current year return filed with all 1099-DA data reconciled, legacy basis documented, DEX activity captured, and methodology aligned with current IRS guidance going forward.

1099-DA Compliance

Case Study

Multiple 1099-DAs with $0 Basis on Transferred Assets, 6 Years of Cost Basis Reconstructed to Correct the Record

Client TypeIndividual Investor with Transferred Assets
Forms ReceivedMultiple 1099-DAs Across Brokers
Reported Basis on Transferred Assets$0 or Blank

The Problem

The client's 1099-DAs reported full gross proceeds with zero or blank cost basis, because the assets had been transferred into the brokers and the brokers had no acquisition data to report. The missing basis turned near-breakeven positions into six-figure paper gains in the picture the IRS would match against. The actual basis traced back six years across roughly 20 wallets and several platforms, some of which no longer existed.

What We Did

We reconstructed cost basis for every transferred asset from originating exchange records, wallet data, and on-chain sources reaching back six years. We established lot-level basis and holding periods, reconciled the rebuilt basis against each 1099-DA, and prepared Form 8949 reporting with documentation supporting each basis figure the brokers could not supply.

The Outcome

The return was filed on documented cost basis rather than the broker-reported blanks, with support retained in case of IRS matching questions. Basis tracking is now in place so future 1099-DAs reconcile on arrival instead of requiring reconstruction after the fact.

Tax Planning

Case Study

$10M+ Portfolio with Project Token Exposure and No Planning Framework Built into Quarterly Strategy

Client TypeHigh-Net-Worth Long-Term Investor
Portfolio$10M+ Including Project Token Positions
EngagementQuarterly Tax Planning

The Problem

Long-term investor with $10M+ portfolio had no framework for RTU tax treatment, no Rev. Proc. 2024-28 alignment, no planning strategy for DeFi income, wallet architecture, or future token events, and no lot-level records to support informed disposition decisions.

What We Did

Reconstructed full portfolio history, documented treatment of all RTU and project token positions, aligned methodology with Rev. Proc. 2024-28, and built a planning framework covering wallet architecture, accounting method, DeFi treatment, and disposition strategy.

The Outcome

Defensible position documented on all major holdings. Quarterly planning engagement now proactively covers disposition timing, loss harvesting, and upcoming token events before they occur.

Crypto Tax Reporting

Case Study

Current Year Filing with Historical Reconstruction, Prior Year Corrections, and 1099-DA Reconciliation

Client TypeHigh-Volume Individual Investor
ActivityMulti-Exchange, Multi-Wallet, DeFi

The Problem

Client engaged for current year filing. Intake revealed incomplete historical cost basis, prior returns with material errors from miscategorized transfers and inconsistent methodology, and 1099-DA data that could not be reconciled against existing records.

What We Did

Reconstructed full transaction history at the tax-lot level, corrected prior year filings with supporting documentation, reconciled all 1099-DA data against rebuilt records, and filed the current year return on a consistent, defensible methodology.

The Outcome

Prior errors corrected. 1099-DAs reconciled. Current year return filed with continuous cost basis records and a methodology that holds up to IRS scrutiny going forward.

IRS Resolution

Case Study

IRS Letter 6174-A with 10 Years of Incomplete Crypto Records Reconstructed and Notice Resolved

Client TypeHigh-Income Individual Investor
NoticeIRS Letter 6174-A
History Reconstructed10 Tax Years

The Problem

Client received IRS Letter 6174-A after a decade of active crypto trading with incomplete accounting. Prior software platforms and CPA firms had failed to produce defensible records. The IRS had third-party data the client could not reconcile and prior filings contained incorrect cost basis and misclassified income.

What We Did

Reconstructed complete digital asset history across 10 years. Identified and corrected specific errors in all prior filings. Filed corrected returns with audit-ready documentation. Drafted and submitted the IRS response. Implemented an ongoing compliance system after resolution.

The Outcome

IRS Letter 6174-A resolved. All prior filings corrected. Client moved from a decade of unresolved exposure to a clean compliance position with ongoing annual reporting.

International Private Client

Case Study

Voluntary Disclosure Coordination, Multi-Year Amended Returns, and Eight-Figure Partner Basis Reconstructed for a Digital Asset Investor

Client TypeHigh-Net-Worth Digital Asset Investor
StructureInvestment Partnership Owning a Foreign Controlled Corporation
EngagementVoluntary Disclosure, Amended Returns, Basis Reconstruction, Ongoing Advisory

The Problem

The client held an interest in a U.S. investment partnership that owned a foreign controlled corporation. The entity and foreign company returns were prepared by separate advisers, and the personal filings had never been reconciled to them. Eight-figure international inclusions had flowed to the individual return across several years, foreign distributions raised questions the personal filings had to answer, and a voluntary disclosure matter was open with outside tax counsel. Beneath all of it, no partner-level basis record existed. The partnership reporting delivered each year does not establish a partner's basis on its own, and without that record a large distribution would be reported as taxable gain against income already taxed once.

What We Did

Our role was the client's personal filings, interpreting the third-party entity reporting and integrating it into the individual returns. We reviewed the historical returns against the partnership and international reporting, coordinated positions with outside tax counsel through the voluntary disclosure process, and prepared multi-year amended returns. When the next cycle brought an eight-figure dividend allocation and a larger distribution, the question was whether the distribution exceeded the client's basis and produced taxable gain, and no record existed to answer it. We reconstructed five years of outside basis from the filed returns, the annual partnership and international reporting packages, distributions, liability allocations, and ownership changes, testing the result against the alternative treatments available.

The Outcome

Historical filings were corrected and aligned with the entity reporting and the voluntary disclosure record. An eight-figure opening outside basis was established, and under the adopted position the distribution did not produce taxable gain. The client holds a permanent file of basis workbooks, technical memoranda, audit defense documentation, and written criteria for when the position should be reopened. Camuso CPA serves as ongoing tax adviser to the client, maintaining the basis record annually, integrating the entity reporting as it arrives each year, and coordinating with the client's other advisers as the structure develops.

Prediction Market Tax

Case Study

$2.1M Kalshi Trading Volume with No Tax Framework and Defensible Position Memo Delivered

Client TypeHigh-Income Individual
PlatformKalshi
Annual Volume$2.1M

The Problem

Client assumed gains from hundreds of Kalshi contract dispositions qualified for Section 1256 treatment by default. No formal tax framework, no transaction-level documentation, and no audit defense position were in place. Exposure included recharacterization across Section 1256, capital, ordinary income, and Section 165(d) frameworks.

What We Did

Performed contract-level classification analysis across all four frameworks. Built a formal position memo with documented rationale for each framework assessed and rejected. Reconstructed the full transaction history and standardized reporting methodology across the entire portfolio.

The Outcome

Defensible reporting position established with audit-ready documentation. Filing consistency delivered across the full portfolio with a methodology the client can carry forward.

Prediction Market Trading

Case Study

Institutional Prediction Market Market-Maker, Millions of Fills, Subledger Built Where No Commercial Tooling Exists

Client TypeMulti-Member LLC, Quantitative Market-Making Firm
ActivityMillions of Fills, Multi-Million-Dollar Annual P&L
VenuesCFTC-Regulated and On-Chain

The Problem

An institutional market-making firm came to us in its second year with trading scaling fast, partnership returns unfiled, and no documented tax positions in an asset class with no controlling guidance. No commercial accounting software supports prediction market venues, and nearly two years of trading activity had never been posted to the books.

What We Did

We designed a proprietary subledger for the regulated venue built for market-making activity, with realized results reconstructed from the complete trading history and traceable back to individual fills. We documented tax positions for both venues with formal written analysis, analyzed self-employment treatment for each partner, and mapped the multi-state filing obligations before preparing any return.

The Outcome

The accounting infrastructure and tax positions were implemented, delinquent partnership filings were brought current, and Camuso CPA manages the firm's ongoing accounting along with quarterly tax projections and provisions.

Prediction Market Tax Advisory

Case Study

Institutional Event Contract Trading, Transaction-Level Tax Framework Built Where No Direct Authority Exists

Client TypeMulti-Member Proprietary Trading Firm
ActivityMillions of Executions Across Multiple Contract Categories
EngagementTax Opinions, Partnership Planning, Evidence Workpapers

The Problem

The firm traded event contracts for its own account through automated systems at institutional scale, across multiple contract categories, with active members in several states and ownership that had changed during the period. Prediction markets sit across derivatives, wagering, property, and partnership rules, and no federal authority directly addresses the specific combination of standardized, centrally cleared, fully collateralized contracts the firm was trading. The firm needed a framework that answered, position by position, what was acquired, when a taxable event occurred, what the legal endpoint was, and which character rules applied.

What We Did

We built the evidence record before reaching tax conclusions, converting the raw trading and organizational material into controlled workpapers covering contract and category inventory, exchange and clearing mechanics, full-population trade analytics, profit attribution, and the ownership and election history. Each position was mapped from acquisition to its authenticated legal endpoint rather than accepting an exchange-generated label as determinative. The framework was developed against primary authority across the full contract lifecycle, testing Section 1256 and option status, Sections 1234 and 1234A, capital asset and sale or exchange requirements, wagering treatment under Section 165(d), and basis and loss allowance. Business status was tested separately from dealer, inventory, and mark-to-market status. The analysis then carried through to the partnership and its members, covering allocations across the midyear ownership changes, capital accounts, member compensation, self-employment and net investment income tax, software development expenditures, and multi-state exposure.

The Outcome

The firm holds a coordinated package of federal and taxpayer-capacity opinions, a partnership and member-level planning memorandum, the supporting evidence workpapers, and a schedule of outstanding information tied to the calculations and filings that depend on it. Positions are classified by contract category and legal endpoint under a documented method, with verified conclusions separated from management representations and unresolved items throughout.

Trading Firm Accounting

Case Study

30 to 50 Million Annual Transactions, Three Years of Accounting Rebuilt on a Crypto-Native Subledger

Client TypeDigital Asset Proprietary Trading Firm
Annual Volume30 to 50 Million Transactions
ScopeThree Years Retroactive, Ongoing Accounting

The Problem

The firm was processing between 30 and 50 million transactions annually against an accounting function that had never been built for that volume. Three years of activity sat unreconciled, and the tooling in place could not handle the data at scale, which left the firm without financials capable of supporting an audit or institutional diligence.

What We Did

We designed a crypto-native subledger built for the firm's transaction volume and reconciliation requirements rather than adapting a general ledger to absorb data it was not built to handle. Three years of historical activity were processed and reconciled through that architecture, with classification applied consistently across the full period. Bespoke automations were built into the close process to remove the manual handling that does not survive at this volume, and the system was structured to support real-time trade tracking rather than periodic batch reconciliation.

The Outcome

Three years of historical accounting were brought current and audit-ready financials delivered. The automations removed more than fifteen hours per month from the close process. The subledger architecture supports the firm's ongoing transaction volume with real-time trade tracking, and it was built to scale rather than to solve the immediate backlog, continuing to carry its compliance and reporting requirements.

Web3 Accounting

Case Study

Web3 Startup Accounting Policy, Subledger Build for Unsupported Chain, and Historical Correction

Client TypeWeb3 Startup (Delaware C-Corp)
GL PlatformXero and Crypto Subledger
ScopePolicy, COA, Historical Correction, Ongoing

The Problem

Web3 startup had prior bookkeeper errors including a SAFE instrument misclassified as a liability, no accounting policy, no chart of accounts, and operated on a proprietary blockchain not natively supported by most crypto subledger platforms, creating a software selection problem before any historical correction could begin.

What We Did

Built accounting policy framework from scratch through multiple versions with institutional review. Selected and confirmed subledger support for the proprietary chain, integrated with the general ledger. Rebuilt historical books, reclassified the SAFE correctly, and built the opening balance sheet on defensible purchase price allocation.

The Outcome

Books rebuilt from scratch with correct methodology. Subledger integrated. SAFE reclassified. Ongoing accounting system in place with documented procedures covering all token and fiat activity.

Accounting and Tax

Case Study

Foreign-Owned DeFi Infrastructure Company, International Tax Exposure Identified, Accounting and Tax System Built from Inception

Client TypeVenture-Backed Delaware C-Corp, Foreign Founders
StructureUS Corporation Plus Offshore Protocol Foundation
EngagementAccounting and Tax

The Problem

A seed-stage DeFi infrastructure company with foreign founders needed accounting and tax support for its US corporation. The company had no books, no accounting policies, and no cost basis tracking, with substantial protocol fees already flowing through a multi-entity structure that was still being formed. It also carried a significant international tax exposure in how the protocol IP had been structured, one no prior advisor had identified, and the decision that would lock in the outcome had not yet been executed.

What We Did

We identified the IP structuring issue while the decision was still open, analyzed the related-party arrangement, and designed the intercompany agreements and reporting framework for a foreign-owned US corporation. We built the accounting system from entity inception, including a digital asset subledger for an actively deployed DeFi treasury with cost basis built from verified on-chain data, and prepared the delinquent filings.

The Outcome

The accounting and tax structure was implemented, delinquent filings were brought current, and Camuso CPA manages the company's ongoing accounting along with quarterly tax projections and provisions.

Accounting Reconstruction

Case Study

Web3 Protocol and Operating Company, Multi-Wallet Accounting Reconstructed and Reconciled to the Blockchain

Client TypeInternational Web3 Operating Company with Related Protocol
ActivityMulti-Chain Wallets, Treasury, Staking, Director Transactions
EngagementFull Accounting Reconstruction and Reconciliation

The Problem

An international Web3 business operating through a company and a related protocol structure had digital asset activity its books could not support. Token transfers at launch appeared to be income but reflected protocol-level allocations. Director withdrawals had been repaid in a different asset mix, leaving loan, distribution, and contribution activity commingled without classification. Staking deposits, rewards, development payments, and treasury movements between wallets remained unclassified, because blockchain records show where assets moved but not the economic substance behind each movement.

What We Did

We performed a transaction-level review of company and protocol activity, tracing wallet flows and confirming the economic substance behind each transaction type. We separated company activity from protocol activity, distinguished director loan activity from distributions and contributions, separated staking principal movements from staking reward income, and applied consistent classification to development costs and returned funds. We built a chart of accounts designed around the actual fact pattern, documented the treatment applied to each category, and reconciled the full record to blockchain data prior to finalization.

The Outcome

A complex multi-wallet accounting file was converted into a structured, supportable set of records reconciled to the blockchain, with documented treatment behind each classification and a reliable foundation for financial reporting, tax preparation, and ongoing accounting.

Web3 Sales Tax

Case Study

Tokenized Collectibles Marketplace Multi-State Sales Tax Assessment and Compliance Framework

Client TypeWeb3 Marketplace
ActivityTokenized Physical Collectibles
ScopeMulti-State U.S. Assessment

The Problem

A marketplace tokenizing physical collectibles on-chain had no nexus analysis, no sourcing framework, and no clarity on whether the taxable event attached to the physical asset transfer, token issuance, or marketplace transaction under each state's rules. Operating with unquantified sales tax exposure across multiple active U.S. markets.

What We Did

Conducted a full multi-state sales tax assessment evaluating nexus thresholds, economic nexus triggers, and state-by-state sourcing rules as applied to tokenized asset transactions. Delivered a written assessment with state-level determinations and a forward-looking compliance framework with registration and filing obligations by jurisdiction.

The Outcome

State-by-state determination delivered with clear guidance on registration obligations, active exposure, and transactions outside state sales tax scope. Compliance framework implemented going forward.

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