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Principles of Blockchain and Cryptocurrency Taxation

Stay up-to-date and compliant with complex federal tax issues involving blockchain and cryptocurrency.

Blockchain technology and cryptocurrency pose several challenges for the application of existing tax law. Although IRS Notice 2014-21 provides a useful baseline rule that taxpayers must apply general tax principles applicable to property transactions to transactions involving cryptocurrency, it suffers from having been issued too early in the evolution of blockchain technology. Specifically, the general rule does not distinguish between asset-backed, intrinsic, utility, or equity cryptocurrency, which poses intricate tax issues when the general rule is applied to several different types of transactions involving cryptocurrency. Each transaction involving cryptocurrency poses complex structuring issues with no cookie cutter solutions. For example, an ICO structure that works for one entity may not work for another. Besides the analysis of an offshore versus onshore structure, it also becomes important to select a proper jurisdiction and entity type (partnership, foundation, corporation, trust, etc.) and determine the tax implications of all the anticipated intercompany transactions, IP development activities, and the transfer of IP. Further, a tax-free transaction for an issuer, whether in an ICO, hard fork, soft fork, or air drop, may be a taxable event for a purchaser (or vice versa), which must be specifically analyzed before structuring a blockchain transaction.

Runtime: 87 minutes
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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

High-Level Understanding of Blockchain Technology and Types of Tokens / Cryptocurrency

Tax Ramification of the General Rule Provided by the IRS Under Notice 2014-21

Understanding the U.S. Federal Tax Implications of Initial Coin Offering / First Token Sales

  • Classification of Tokens as Equity vs. Debt for Tax Purposes
  • Characterization of Income (Sale, License, or Service)
  • Determination Whether the Issuer Should Be a U.S. Issuer or a Foreign Issuer and the Tax Implications of Using Domestic Entity vs. Foreign Entity
  • Timing of Income Inclusion for Issuers and Purchasers

Understanding the Tax Implications for Token Purchasers and Traders

Tax Implications on Transfer of Intellectual Property in a Blockchain Project

Discussion on Certain U.S. Anti-Deferral Tax Issues Such as the Controlled Foreign Corporation and Passive Foreign Investment Company Rules Applicable to Cryptocurrency Transactions Involving Foreign Entities

  1. S. Tax Issues Involving U.S. and Foreign Traders in Cryptocurrency
    1. S. Federal Tax Implications of Hard Forks, Soft Forks, and Air Drops
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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Webinar

This course was last revised on August 22, 2019.

Call 1-866-352-9540 for further credit information.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

Audio & Reference Manual

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.5
     
  • NJ CLE 1.8
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.5
     
  • WV MCLE 1.8
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.5
     
  • NJ CLE 1.8
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.5
     
  • WV MCLE 1.8
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 32 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Pallav Raghuvanshi

Pallav Raghuvanshi

Greenberg Traurig, LLP

  • Handles U.S. federal tax aspects of initial coin offering/first token sales and other tax-related issues on blockchain technology and cryptocurrencies at Greenberg Traurig LLP
  • Frequently writes about the intricate tax issues (both domestic and cross-border) involving blockchain and cryptocurrency and is a co-author of an article titled Blockchain and Cryptocurrency: Federal Income Tax Issue, which was published in Tax Notes in November 2018
  • Regularly speaks on the complex federal tax issues involving blockchain and cryptocurrency at seminars and CLEs
  • Serves as an editorial board member of Greenberg Traurig’s Blockchain and Cryptocurrency Newsletter
  • Has been Listed, Super Lawyers magazine, New York Metro Super Lawyers, Rising Stars, 2017-2019
  • LL.M. degree in international taxation, New York University School of Law; B.B.A. and LL.B. degrees, with distinction, Symbiosis Law School
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Product ID: 404972
Published 2019
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