Fork it over: IRS guidance reaffirms crypto position regarding significance of dominion and control in determining “virtual” accessions to wealth following hard forks

On April 9, 2021, the Internal Revenue Service (Service) released Chief Counsel Advice 202114020 (the Guidance) regarding the tax consequences to an individual in receipt of Bitcoin Cash (BCH) following the August 2017 hard fork of Bitcoin (BTC). In the Guidance, the Service largely reaffirms its historic position regarding the treatment of cryptocurrencies as property, and the tax treatment of new cryptocurrencies actively or constructively received by taxpayers after a hard fork that creates...
By: Eversheds Sutherland (US) LLP

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