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CCA 202114020 addresses the tax consequences of bitcoin's
2017 "hard fork," which created bitcoin cash. Under the
CCA, taxpayers who received bitcoin cash as a result of the hard
fork had gross income when they had "dominion and
control" over the bitcoin cash.
The CCA clarifies Revenue Ruling 2019-24. Under that ruling,
taxpayers had gross income as a result of a hypothetical hard fork
followed by an "airdrop." Some taxpayers wondered whether
the ruling applied equally to non-airdrop events. In response, the
CCA provides that "the specific means by which the new
cryptocurrency is distributed or otherwise made available to a
taxpayer following a hard fork does not affect the Revenue
Ruling's holding."
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
