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The IRS has not consistently held that the ability to exchange property, even investment property, demonstrates sufficient control to trigger income recognition. A taxpayer can sell a book, and that book may increase in value dramatically from the date it is received.
Where the taxpayer stores that book, whether boxed in their basement or proudly displayed in their library, does not significantly alter their ability to sell it. However, the IRS appears to assert that storage of cryptocurrency in a form where it is accessible for sale leads to income recognition. Depending on what type of property one thinks cryptocurrency is most analogous to, IRS positions in the Hard Fork CCA may be subject to future challenge in several respects, including with regard to the taxable event itself and its timing.
If the IRS continues to assert these positions, future guidance should provide a clear articulation of why cryptocurrency is distinct from other forms of property and why these distinctions require different tax results.
Guidance is particularly critical in light of the growing variety, value and popularity of digital assets evidenced by the recent boom in non-fungible tokens commonly referred to as NFTs. Practice Point: Despite its increasing popularity and constant attention in the media, guidance on the taxation of cryptocurrencies is developing very slowly. If you are investing or thinking about investing in cryptocurrencies, you should consider and prepare for their tax consequences.
For example, if your cryptocurrency experiences a hard fork, the IRS appears to believe that you have a taxable event and owe federal income tax on the value of the new cryptocurrency created from the hard fork. Failure to report the income could subject you to penalties and interest.
If the IRS can prove you failed to report the income purposely, you might be facing criminal penalties. With careful and deliberate planning and advice, you can avoid some of the pitfalls that have befallen thousands of cryptocurrency investors. For additional information on the taxation of cryptocurrencies, please see our analysis of virtual currency staking activities , virtual currency mining activities and analysis on our Tax Controversy blog.
Andrew R. Kevin Spencer. By Andrea Kramer , John T. Lutz , William R. Pomierski and Kevin Spencer on May 6, Andrea Kramer Andrea Andie S. Kramer has a sophisticated and unique multi-disciplinary legal practice that covers all aspects of financial transaction, derivatives, and cryptocurrency, with a focus on taxation, regulation, contract design, trading operations and documentation.
Andie helps clients successfully resolve difficult legal situations, including federal and state regulatory matters, adversarial proceedings, and tax planning and compliance issues while addressing interrelated business objectives, regulatory and legal requirements, and public policy. John T. Lutz John T. Lutz advises clients on federal and state taxation, particularly the taxation of structured finance, derivative, structured products and hedge funds.
He also counsels clients on matters related to tax examinations and controversies, insurance products, investment tax credits, conventional US and cross-border securities offerings, and corporate mergers and acquisitions. John is partner-in-charge of the New York office. Read John T. William R. Pomierski William Bill R.
Pomierski focuses his practice on the taxation of financial products and capital markets transactions, as well as on executive compensation matters. Bill advises clients on the federal income tax implications of a variety of domestic, cross-border and global financial products and related transactions.
Kevin Spencer Kevin Spencer focuses his practice on tax controversy issues. We may be compensated when you click, sign up for, deposit, or spend on a given platform. Learn more. In simple terms : A hard fork is when a single cryptocurrency splits in two. SegWit is an example of a Bitcoin soft fork meant to create two compatible versions of the software that share a single asset. SegWit is backwards compatible. Bitcoin Cash is a Bitcoin hard fork that was meant to create two different assets with value.
After the fork occurred, Bitcoin Cash and Bitcoin became two totally different cryptocurrencies from the activation block forward. With that covered, it is important to note that not every hard fork is meant to create a new coin with value. Byzantium was a mandatory upgrade to the Ethereum software. With Byzantium the old software the old blockchain and the token on it was not meant to be used after the activation block.
After Byzantium, there was still only one Ethereum. One last note, ultimately we are talking about software here. And that means the specifics of each fork comes down to code. Quick rules for forks : If you want to ensure you have access to a fork, be in a wallet where you control your private keys and then follow these steps for claiming a fork. If you are running a node the full version of the software; the type where you download the blockchain , you MUST update your client before the fork.
On Airdrops : A fork is when a coin splits in two. An airdrop is when coins are sent to an existing wallet for any reason. Although you might hear the two words used interchangeably in casual conversation, an airdrop is different than a fork.
Learn about airdrops. With all the above in mind, to use the words of Coinbase when discussing a User Activated Soft Fork , and too add a few of our own notes, the result of a given soft fork or hard fork would generally be:. Any of the above cases can occur with a given fork, but the 3rd option is the most common and thus the expected outcome over time with hard forks that create new cryptocurrencies.
Again, Bitcoin Cash a Bitcoin fork and Ethereum a fork of what we now call Ethereum Classic are good examples of the expected outcome of hard forks that are meant to create two assets with market value. Both chains exist, but one is more popular and generally maintains a higher value.
Meanwhile, a soft fork like SegWit is generally meant to be the second case and a hard fork like Byzantium is always meant to be the first case. Why forks produce free coins : A blockchain is a ledger of transactions and is where the ownership of coins is recorded. Anyone who held coins before a fork, and during the fork, therefore will necessarily have coins on both chains after the fork has occurred.
The snapshot happens at a block number, the block number is important with forks, the calendar date is only important for understanding when the block number occurred. It is not necessary to hold the original coin after the snapshot has occurred. In cryptocurrency, a soft fork is a minor change to the software that is not necessary for all nodes computers running software to update to.
Meanwhile, a hard fork is a term that describes a major change to the blockchain protocol that can fundamentally change the way a crypto network works it can roll back transactions, it can change the way mining works, etc. This can be used to keep the same coin with major changes to the blockchain or to create a new coin.