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New Cryptocurrency Guidance: Identifying Units, Hardforks, and Airdrops

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, January 14, 2020

Recorded event now available

or call 1-800-926-7926

This course will discuss recently released IRS Revenue Ruling 2019-24 and the updated FAQs regarding taxation of cryptocurrency. With only Revenue Ruling 2014-21 for guidance, practitioners and holders of virtual currency welcomed the release of updated guidance on the taxation of cryptocurrency. Our adept panel will clarify the recent guidance, explain best practices to document these cumbersome transactions, and discuss the recent IRS initiative to identify and tax virtual currency activity.


In its short--5 page--Revenue Ruling 2019-24, the IRS attempts to answer questions surrounding receipt of cryptocurrency. Specifically, the Revenue Ruling asks and answers two questions:

  • Is a hardfork subject to tax when the taxpayer doesn't receive new cryptocurrency?
  • Is an airdrop following a hardfork subject to tax when the taxpayer receives new cryptocurrency?

The Revenue Ruling provides an explanation and a situational example of each question. The guidance explains that cryptocurrency from an airdrop is taxable when the taxpayer can exercise "dominion and control" over the currency, not necessarily when the transaction is recorded in the distributed ledger (i.e., blockchain).

In addition to this October 2019 Revenue Ruling, the IRS expanded its FAQ, adding 27 questions and answers concerning taxation of cryptocurrency. One pertinent answer is that a taxpayer can specifically identify units sold.

The Q&A also covers new information on gain/loss calculations, gifts of cryptocurrency, and charitable donations of these units.

Listen as our expert panel reviews the October 2019 IRS guidance on cryptocurrency, including calculating gains and losses, accurately handling the taxation of hardforks and airdrops, and the questions that remain surrounding taxation of these virtual units.



  1. Cryptocurrency: what we knew
  2. New Revenue Ruling 2019-24
  3. 27 new FAQs
  4. Current IRS focus on cryptocurrency
  5. Questions remaining


The panel will review these and other important issues:

  • When is a hardfork taxed?
  • What is the state of the current IRS initiative to tax virtual currency transactions?
  • How should holders document virtual transaction activity?
  • How and when are airdrops taxed?


Davis, Evan
Evan J. Davis

Hochman Salkin Toscher Perez

Mr. Davis represents individuals and closely held entities in criminal tax investigations and prosecutions, foreign...  |  Read More

Stein, Michel
Michel R. Stein

Hochman Salkin Toscher Perez

Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For...  |  Read More

Toscher, Steven
Steven (Steve) Toscher

Managing Principal
Hochman Salkin Toscher Perez

Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions...  |  Read More

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