On October 9, 2019, the IRS released Revenue Ruling 2019-24,
which provides guidance with respect to hard forks and airdrops of
cryptocurrency, and new frequently asked questions (FAQs), which
provide guidance on other cryptocurrency issues. Rev. Rul. 2019-24
and the new FAQs represent the most significant cryptocurrency
guidance the IRS has published since the limited guidance provided
five years ago in Notice 2014-21, which sets forth the IRS position
that virtual currency should be treated as property rather than
currency for U.S. federal income tax purposes.
Taxpayers involved in investing in, trading, or creating
cryptocurrency assets should find the new guidance a worthwhile
read. While this guidance is helpful, the FAQs are focused on
reiterating the application of basic income tax principles to
cryptocurrency transactions. More complicated technical questions
are largely left unaddressed. As a result, taxpayers will have to
continue to seek advice from their
