Bitcoin: Property or Currency?

8 Pages Posted: 26 Dec 2015

Date Written: August 24, 2015


Bitcoin, a virtual currency created in 2009 by an individual or group using the alias Satoshi Nakamoto, is based on a decentralized peer-to-peer system. Transactions are made with no intermediary. There are no banks involved, little to no transaction fees, and transactions are almost instantaneous. Transactions are verified by network nodes, and the network uses a public ledger called the block chain to record transactions. There is no central repository or administrator. Treasury categorizes it as a decentralized virtual currency.

As public acceptance increases, so too does the number of merchants willing to accept bitcoin as a form of payment. But even though the public is slowly embracing bitcoin as a form of payment (thus giving it characteristics of a currency), public officials continue to struggle with the question of whether bitcoin is a currency — and therefore subject to appropriate currency regulations — or if it is simply property, making transactions in bitcoin more akin to barter.

Keywords: bitcoin tax, bitcoin taxation, taxation of bitcoin, cryptocurrency tax, tax of cryptocurrencies, tax of bitcoin

Suggested Citation

McCullum, Esq., Paul, Bitcoin: Property or Currency? (August 24, 2015). Tax Notes, Vol. 148, No. 8, 2015, Available at SSRN: or

Paul McCullum, Esq. (Contact Author)

McCullum Law Office ( email )

Santa Monica, CA 90408
United States
747-444-2889 (Phone)

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