Bitcoin Loans and Other Cryptocurrency Tax Problems

摘要

This article considers the U.S. federal income tax treatment of loans and prepaid forward contracts denominated in cryptocur-rencies. There is substantial uncertainty as to how the IRS will treat these products. The author examines traditional authorities regarding loans and prepaid forward contracts, as well as particular problems that arise in designing financial products referencing cryptocurrencies, and provides general principles that, if followed, can improve the possibility that these products will be taxed as intended.