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IRS guidance on virtual currency transactions

Insight Melinda Fellner Bramwit Melinda Fellner Bramwit · January 22, 2020

The last word taxpayers engaging in virtual currency transactions heard from the IRS was in 2014 in Notice 2014-21. Please review our commentary on the notice here. Now, five years later, the IRS has issued two new pieces of guidance for taxpayers in this area in the form of Revenue Ruling 2019-24 and a set of questions and answers on the subject. The Ruling itself centers on issues involving the hard fork, i.e. when a cryptocurrency on a distributed ledger undergoes a protocol change resulting in a permanent diversion from the legacy or existing distributed ledger. The IRS question and answer link supplements issues addressed in Notice 2014-21. Taxpayers involved in any virtual currency transactions should contact us for advice in connection with these two important pronouncements.

Revenue Ruling 2019-24.

Click here to access the IRS Q&A.


Melinda Fellner Bramwit focuses her practice on tax matters including federal, state and international tax. Ms. Bramwit's experience includes business structuring, acquisitions and reorganizations, and joint ventures and partnerships in both the domestic and offshore world. This experience includes negotiating and drafting operating agreements and drafting organizational and transactional documents for corporate transactions. She has cultivated specific expertise in the international arena, including guiding affected clients through the IRS Streamlined Offshore Programs and the IRS Offshore Voluntary Disclosure Program and assisting with other offshore income issues. Additionally, Melinda routinely represents clients in federal and state tax controversies. Read more.

Attorney Advertising. This document is not intended to be and is not considered to be legal advice. Transmission of this document is not intended to create, and receipt does not establish an attorney-client relationship. Prior results do not guarantee a similar outcome.