The US Treasury Department and Internal Revenue Service (IRS) have filed 45 claims worth $44 billion against bankrupt cryptocurrency exchange FTX and its subsidiaries.
In tax returns from FTX sister company Alameda Research LLC that circulated online on May 10, the IRS assessed the company for $20.4 billion in partnership and payroll taxes. The assessment appears to match the IRS claim on the website of Kroll's Restructuring Management Practice, FTX' s claims agent.
The IRS filed another $7.9 billion in claims against Alameda Research LLC, while two claims -- $7.5 billion and $2 billion -- were filed against Alameda Research Holdings. The IRS files claims under an "administrative priority," enabling its claims to supersede th rose of unsecured creditors in bankruptcy proceedings. Although Alameda Research is headquartered in Hong Kong, its founders and key personnel, including Sam Bankman-Fried and Caroline Ellison, are US citizens. Unlike most other countries, the United States operates a tax-by -citizenship system , which means that US nationals are obliged to pay taxes on their worldwide income, regardless of where they live or how long they spend in the US each year. For partnership entities, the tax is not paid at the partnership level,but is passed through its partners and taxed at the individual level.
In April, FTX had recovered $7.3 billion in assets and would consider restarting the exchange next year. The announcement came ahead of the IRS claim, at a time when FTX's liabilities still exceeded its assets by approximately $8.7 billion.
