The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 16

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Elizabeth McMorrow, JD, LL.M., owner at Elizabeth McMorrow Law, LLC. Prior to starting her law firm, Elizabeth served as in-house counsel at The Coca-Cola Company and Genzyme Corporation, a member of the Markit|CTI legal advisory team, a Senior Associate with Dewey Ballantine, and a clerk at the U.S. Court of International Trade.

Tune in for these key takeaways:

• A brief explanation and history of FATCA (Foreign Account Tax Compliance Act), CRS (Common Reporting Standard), and CARF (Crypto-Asset Reporting Framework).

• A discussion of the state of CARF and several theories and predictions on what may be in store for the future of CARF reporting.

• Insight into the current impact that FATCA has on US ex-pats.

• Dialogue around the duplicative nature of the FBAR and Form 8938 and possibilities for the future of these two reporting mechanisms.

• Common issues with the current impact of FATCA on banks, hedge funds, assets, trusts, and fund administrators.

• Discussion about current impact of CARF in the digital asset space.

An outline of situations where multi-jurisdictional reporting may be required and strategies for navigating.

Learn more about Elizabeth McMorrow:

• Visit the About page on Elizabeth McMorrow Law LLC’s website: https://www.elizabethmcmorrowlaw.com/biography

• Connect with Elizabeth McMorrow on LinkedIn: https://www.linkedin.com/in/elizabethmcmorrow/

• Peruse Elizabeth’s Blog Posts on Elizabeth McMorrow Law LLC’s website: https://www.elizabethmcmorrowlaw.com/blog

Further Resources:

• IRS Foreign Account Tax Compliance Guidance: https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca

• IRS Form 8938 Guidance: https://www.irs.gov/forms-pubs/about-form-8938

• FinCEN FBAR Guidance: https://www.fincen.gov/report-foreign-bank-and-financial-accounts

• White Paper: Who Reports Cryptocurrency to the IRS? - https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4261066

• 2025 White House Strengthening American Leadership in Digital Financial Technology - https://www.whitehouse.gov/wp-content/uploads/2025/07/digital-Assets-Report-EO14178.pdf

• 2025 Testimony of Lawrence Zlatkin, Vice President, Tax, Coinbase Global, Inc. - https://www.finance.senate.gov/imo/media/doc/100125_zlatkin_testimony.pdf

• Digital Asset PARTIY Act, U.S. Congressman Max Miller - https://maxmiller.house.gov/posts/congressman-max-miller-releases-bipartisan-legislation-to-modernize-tax-treatment-of-digital-assets

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa