Taxing Blockchain Forks

27 Pages Posted: 8 Nov 2019

See all articles by Mattia Landoni

Mattia Landoni

China Europe International Business School (CEIBS)

Gina C. Pieters

Digital Economy Research & Consulting

Date Written: October 25, 2019

Abstract

The tax treatment of cryptocurrency forks presents four unique challenges: parent/child designation, taxpayer access to the new token, assessment of fair market value, and assessment of comparable contemporaneous fair market values. We provide empirical evidence that each of these issues is a hurdle in determining whether income has been realized, or in apportioning the basis. We consider three existing approaches for assets acquired without a purchase. We conclude that the least problematic approach (adopted by Japan) is giving zero tax basis to the new coin and taxing the proceeds upon a sale, while treating the new coin as realized income (as recently ruled in the US) is the most problematic.

Keywords: taxation, cryptocurrency, fork, split, blockchain, distributed ledger

JEL Classification: H20, H21, H24, H29

Suggested Citation

Landoni, Mattia and Pieters, Gina C., Taxing Blockchain Forks (October 25, 2019). SMU Cox School of Business Research Paper No. 19-18, Available at SSRN: https://ssrn.com/abstract=3475598 or http://dx.doi.org/10.2139/ssrn.3475598

Mattia Landoni

China Europe International Business School (CEIBS) ( email )

Shanghai-Hongfeng Road
Shanghai 201206
Shanghai 201206
China

HOME PAGE: http://https://www.ceibs.edu/mattia_landoni

Gina C. Pieters (Contact Author)

Digital Economy Research & Consulting ( email )

Chicago, IL
United States

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