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OnDemand Course

Principles of Blockchain and Cryptocurrency Taxation

Gain an understanding of current and potential future cryptocurrency reporting requirements.

Blockchain technology and cryptocurrency pose several challenges to 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. The general rule does not distinguish between asset-backed, intrinsic, utility, or equity cryptocurrency. This poses intricate tax issues when the general rule is applied to several different types of cryptocurrency transactions. Each transaction involving cryptocurrency poses complex structuring issues with no cookie-cutter solutions. For example, a token issuance 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 any token issuance, hard fork, soft fork, or airdrop, may be a taxable event for a purchaser (or vice versa), which must be specifically analyzed before structuring a blockchain transaction. The presentation will touch on the latest issues involving decentralized finance, staking, etc., and will include an overview of current and potential future cryptocurrency reporting requirements.

64 minutes
Course Exam
Certificate of Completion
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Why Lorman?

Over 37 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/Cryptocurrencies

Tax Ramifications 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 of Decentralized Finance

Tax Implications on Transfer of Intellectual Property in a Blockchain Project

  1. S. Tax Issues Involving U.S. and Foreign Traders in Cryptocurrency
  2. Understanding the Reporting Requirements Under the Infrastructure Investment and Jobs Act

    1. S. Federal Tax Implications of Hard Forks, Soft Forks, and Airdrops
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Why Lorman?

Over 37 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

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Maine, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

This course was last revised on February 7, 2023.

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

  • AIPB 1.0
     
  • This program is acceptable for 1.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     
  • AR CLE 1.0
     
  • This course has been approved for 1.0 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.0
     
  • The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.0 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.0
     
  • Lorman Business Center, LLC. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.0 CLE hours of participatory credit.
     
  • CT CLE 1.0
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.0 CLE credit(s).
     
  • GA CLE 1.0
     
  • This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.0 CLE hours.
     
  • HI CLE 1.0
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.0 CLE credit hours.
     
  • MO CLE 1.3
     
  • This course qualifies for self-study CLE credit in Missouri.
     
  • NH MCLE 1.0
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 64 Minutes.
     
  • PA CLE 1.0
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.0 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 1.0
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.0 hours of CLE credit.
     
  • VT CLE 1.0
     
  • This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.0 hour(s) of CLE credit. Please note: Attorneys may only claim 12 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
     
  • WI CLE 1.0
     
  • This program qualifies for 1.0 hour(s) of ondemand CLE through the WI Board of Bar Examiners.
     
  • WV MCLE 1.3
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.3 MCLE hours.
     

To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.

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

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Why Lorman?

Over 37 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

Shira Peleg

Shira Peleg

Greenberg Traurig, LLP

  • Represents clients before the IRS and state and local taxing authorities in examinations, appeals, court, and collections
  • Serves as co-chair of the New York City Bar Association Personal Income Taxation Committee
  • Listed, The Best Lawyers in America, Ones to Watch, Tax Law, 2023
  • J.D. and LL.M. degree in taxation, New York University School of Law; B.A., Barnard College
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
  • Regularly speaks on the complex federal tax issues involving blockchain and cryptocurrency at seminars and CLEs
  • Listed, The Best Lawyers in America, Once to Watch, Tax Law, 2021-2022
  • 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. degree, with distinction, Symbiosis Law School
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Why Lorman?

Over 37 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.

All of your training, right here at Lorman

All of your training, right here at Lorman.

Pay once and get a full year of unlimited training in any format, any time!

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Product ID: 410097
Published 2023
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