Hello all,
DUNI is current on its prior period Form 1120 tax return filings and payments. Its tax obligations were primarily driven by outbound dispositions of award that were not deductible for tax purposes, which is expected to be non-recurring in future periods because treatment for U.S. tax purposes will be a known consideration for governance proposals. Accordingly, future governance proposals with unfavorable tax treatment will be a consideration in whether or not the proposal should pass.
DUNI has made payment for all income tax owed, interest and penalties as calculated by the IRS. However, DUNI has submitted Forms 843 to request abatement of penalties resulting from reasonable cause and extraordinary circumstances related to the taxation of DAOs during this period. While interest is generally not eligible for abatement, DUNI is in the process of requesting a recalculation of some of the interest periods and percentages as initially calculated by the IRS.
At present, DUNI is engaged in a Request for Private Letter Ruling (PLR) with the IRS related to its election for corporate tax treatment because the periods in question extended beyond what could be addressed through filing a Form 8832.
Upon successful resolution of the PLR, Cowrie - Administrator Services will provide all filed tax returns as part of their quarterly financial disclosures.
The 2025 tax return will be provided to the community prior to filing for their review and as an opportunity to ask any questions.
Justin