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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.

Learning Objectives

  • You will be able to identify fundamentals of blockchain
  • You will be able to differentiate between token types
  • You will be able to identify tax implications such as hard fork, soft forks, and Air Drops
  • You will be able to identify tax implications such as Controlled Foreign Corporations

Runtime: 87 minutes
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Why Lorman?

Over 33 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 33 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 Course

This course was last revised on October 23, 2019.

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

  • CPE/NASBA - QAS Self Study 2.0 including Specialized Knowledge 2
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a QAS Self Study sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 2.0 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Specialized Knowledge for 2.0 hours. Prerequisite: basic knowledge of general accounting. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: QAS Self Study. Please refer to the information in this advertisement for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board.
     
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Why Lorman?

Over 33 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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Why Lorman?

Over 33 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.

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Product ID: 407093
Published 2019
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