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.
Add to Wishlist
Credit
More Program Information
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
- S. Tax Issues Involving U.S. and Foreign Traders in Cryptocurrency
- S. Federal Tax Implications of Hard Forks, Soft Forks, and Airdrops
Understanding the Reporting Requirements Under the Infrastructure Investment and Jobs Act
Add to Wishlist
Credit
More Program Information
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
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 Education Services 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.
- 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.
- 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".
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.
Add to Wishlist
Credit
More Program Information
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
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
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
Add to Wishlist
Credit
More Program Information
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.
Pay once and get a full year of unlimited training in any format, any time!
- OnDemand Courses
- Live Webinars
- MP3 Downloads
- Course Manuals
- Executive Reports
- White Papers and Articles
Additional benefits include:
- State Specific Credit Tracker
- All-Access Pass Course Concierge
Questions? Call 877-296-2169 to speak with a real person.
Access to all training products for one year
$699/year
Unlimited Lorman Training
With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!
Easy Registrations
Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.
Invest in Yourself
You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.
