IRS asserts $44B from FTX bankruptcy

The United States Department of the Treasury and the Internal Revenue Service (IRS) has filed 45 claims totaling $44 billion against FTX and its subsidiaries.

In what appears to be a tax statement for FTX’s sister company, Alameda Research LLC, that was circulating online on May 10, the IRS assessed the company with $20,4 billion in partnership taxes and payroll taxes due.

The assessment appears to correspond with the IRS claim discovered on the website of FTX’s claims agent, Kroll’s Restructuring Administration practice.

The IRS asserts a further $7.9 billion claim against Alameda Research LLC, while it asserts $7.5 billion and $2.0 billion against Alameda Research Holdings.

The Internal Revenue Service submitted its claims under “administrative priority,” allowing its claims to take precedence over those of unsecured creditors during bankruptcy proceedings.

Although Alameda Research was headquartered in Hong Kong, its founders and essential personnel, such as Sam Bankman-Fried and Caroline Ellison, are American citizens.

In contrast to most other nations, the United States employs a taxation-by-citizenship regime, meaning that U.S. nationals are taxed on their worldwide income regardless of where they reside or how much time they spend in the United States each year.

For partnership entities, taxes are not paid at the partnership level; instead, they are transmitted to the partners and taxed at the individual level.

In April, it was reported that FTX had recouped $7.3 billion in assets and would contemplate relaunching the exchange the following year.

At the time of the announcement, FTX’s liabilities still exceeded its assets by approximately $8.7 billion.