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Principles of Blockchain and Cryptocurrency Taxation (OnDemand Webinar)

Name: Principles of Blockchain and Cryptocurrency Taxation (OnDemand...
SKU: 410097EAU
Availability: InStock

$149.00

SKU: 410097EAU

Description

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 201421 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 assetbacked, 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 cookiecutter 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 taxfree 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.

Date: 2023-02-07 Start Time: End Time:

Learning Objectives

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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

U.S. Tax Issues Involving U.S. and Foreign Traders in Cryptocurrency

Understanding the Reporting Requirements Under the Infrastructure Investment and Jobs Act

U.S. Federal Tax Implications of Hard Forks, Soft Forks, and Airdrops

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AIPB ,CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.

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Shira Peleg-Greenberg Traurig, LLP, Pallav Raghuvanshi – Greenberg Traurig, LLP

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Principles of Blockchain and Cryptocurrency Taxation (OnDemand Webinar)

$219.00

SKU: 407093EAU

Description

Stay uptodate and compliant with complex federal tax issues involving blockchain and cryptocurrency.Blockchain technology and cryptocurrency pose several challenges for the application of existing tax law. Although IRS Notice 201421 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. Specifically, the general rule does not distinguish between assetbacked, intrinsic, utility, or equity cryptocurrency, which poses intricate tax issues when the general rule is applied to several different types of transactions involving cryptocurrency. Each transaction involving cryptocurrency poses complex structuring issues with no cookie cutter solutions. For example, an ICO 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 taxfree transaction for an issuer, whether in an ICO, hard fork, soft fork, or air drop, may be a taxable event for a purchaser (or vice versa), which must be specifically analyzed before structuring a blockchain transaction.

Date: 2019-10-23 Start Time: End Time:

Learning Objectives

High-Level Understanding of Blockchain Technology and Types of Tokens / Cryptocurrency

Tax Ramification 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 on Transfer of Intellectual Property in a Blockchain Project

Discussion on Certain U.S. Anti-Deferral Tax Issues Such as the Controlled Foreign Corporation and Passive Foreign Investment Company Rules Applicable to Cryptocurrency Transactions Involving Foreign Entities

U.S. Tax Issues Involving U.S. and Foreign Traders in Cryptocurrency

U.S. Federal Tax Implications of Hard Forks, Soft Forks, and Air Drops

No Credit Available

Pallav Raghuvanshi-Greenberg Traurig, LLP

Principles of Blockchain and Cryptocurrency Taxation (OnDemand Webinar)

$219.00

SKU: 404972EAU

Description

Stay uptodate and compliant with complex federal tax issues involving blockchain and cryptocurrency.Blockchain technology and cryptocurrency pose several challenges for the application of existing tax law. Although IRS Notice 201421 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. Specifically, the general rule does not distinguish between assetbacked, intrinsic, utility, or equity cryptocurrency, which poses intricate tax issues when the general rule is applied to several different types of transactions involving cryptocurrency. Each transaction involving cryptocurrency poses complex structuring issues with no cookie cutter solutions. For example, an ICO 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 taxfree transaction for an issuer, whether in an ICO, hard fork, soft fork, or air drop, may be a taxable event for a purchaser (or vice versa), which must be specifically analyzed before structuring a blockchain transaction.

Date: 2019-08-22 Start Time: End Time: