Document Type

Article

Publication Date

1-13-2020

Abstract

The IRS recently issued its second description of how it will treat Bitcoin and other blockchain assets. Some of its analysis leaves open questions that invite further consideration, and important issues remain unresolved. Moreover, because the popular Bitcoin blockchain uses a "proof of work" consensus procedure, issues relating to the alternative "proof of stake" procedure have been neglected.

Keywords

Law & economics, income taxation, securities registration, cryptocurrency, blockchain, Internal Revenue Service, IRS, Securities & Exchange Commission, SEC, location of economic activity, business entities, proof of work, PoW, proof of stake, PoS, decentralized autonomous organization, DAO

Publication Title

Tax Notes Federal

Publication Citation

Tax Notes Fed., at 241 (Jan. 13, 2020).

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