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.
Agenda
Faculty
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
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
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