
In this Crypto Forces segment of Hidden Forces, Demetri Kofinas speaks with Mark DiMichael, a Forensic Accountant with Citrin Cooperman, who specializes in the tax implications for cryptocurrencies. What are the filing requirements for anyone who has p...
Loading summary
A
Foreign. What's up, everybody? Welcome to this week's Crypto Forces segment of the Hidden Forces podcast, where I speak with engineers, investors, entrepreneurs, and anyone else from the world of cryptocurrencies and distributed consensus. Today I speak with Mark demichel, a forensic accountant with Citron Cooperman who specializes in the tax implications for cryptocurrencies. We're going to talk about taxable events like Kind Exchange and what the filing requirements are for anyone who has profited from, transacted in, or mined a cryptocurrency at any point in the last nine years. This is an incredibly informative and timely discussion, so let's get right to it. Mark, welcome to Hidden Forces.
B
Thank you, Dimitri.
A
It's great having you on, man.
B
Definitely glad to be here.
A
Do you remember when you and I first met?
B
I believe it was about a month and a half ago at one of those Crypto circle networking events.
A
We were at Richie Heckler's cryptocurrency working group.
B
Oh, right, correct.
A
Yeah, yeah. The group was founded with Richie, and he did it at Goldman Sachs. With Goldman. And it was like a group of like, 20 people. And there was someone from Hashgraph. So that's how I came across Hashgraph. We met at Andrew Masanto's apartment, where there were like, 100 people or something. And I overheard you talking to a couple of guys who were trying to ask you what they're supposed to do with cryptocurrencies and taxes and stuff like that. And they were specifically talking about, like, Kind Exchange, because they're talking about, like, if I had some Bitcoin and I bought some ico, I used it in an ico, and I got a different cryptocurrency. Do I have to pay? And you were responding, and you sounded like you really knew your shit. I was like, this guy really knows his shit on taxes. I haven't heard anyone talk about taxes. I gotta pick this guy's brain. So I picked your brain. Turns out you're also a nice guy, and I thought it would be great to have you on because I haven't been able to find anyone or anything, any real source to talk about taxes. So I want to sort this out with you a little bit. Right, Definitely. Now, you, as I mentioned in the audience, you're sort of an autodidact on this. You're an accountant, but you're a forensic accountant, but you specialize in taxes, among other things, right?
B
Well, originally, I was a fraud and forensic accountant, and that was how I got into this to begin with. Back in the day, this is mainstream now, but back in the day, this was underground, criminal fraud type stuff.
A
Cryptocurrencies.
B
Cryptocurrencies, yeah. So that's when I first became interested in it. Wanted to learn more about it, and that's why I'm a good bit ahead of the curve compared to most accountants on how to.
A
I didn't know that aspect of the story. So when did you start looking into this? When did you start doing this as part of your forensic work?
B
Well, I haven't had any forensic cases dealing with it yet. I'm sure it's ones coming down the pipe, I'm sure, but. But it was just staying current in the field. I knew this was where it was at as far as, you know, fraud and money laundering. I wanted to stay current, so I began learning about that.
A
What did you tell me? I didn't educate myself properly on this. You sent me an article. But there's some dispute as to whether or not money laundering is. What is this? What is this thing?
B
There was actually a Florida court that ruled about a year, I believe it was about a year and a half ago that bitcoin was not money, so it couldn't be laundered. And they had a guy in Florida, they were trying this guy for money laundering, and the judge basically threw the case out. Florida subsequently passed legislation saying for purposes of money laundering, this stuff counts.
A
That's so funny. So let me ask you something. That's so funny. Let me ask you something. Are you telling me that back then, if I had a million dollars and I turned it into bitcoin and I moved it from here to Colombia and I turned into cash there, that I wouldn't have been able to get prosecuted for money laundering, but I could have gotten prosecuted for tax evasion?
B
Well, there's different. That was a Florida court. Different jurisdictions might feel differently about it.
A
But if it was in Florida, let's say.
B
But if it was in Florida, arguably you could have been that guy who got away with it.
A
But I would have been charged for tax evasion.
B
Oh, absolutely. I mean, tax evasion is.
A
Because there would have been some small gain, potentially speaking, if there was a gain when I went and laundered the money, if the currency increased in value and I cashed out on it. Right.
B
Well, you could have gotten the money illegally and still paid taxes on it and then laundered it, and then you would not be guilty of tax evasion. But most criminals tend not to pay taxes.
A
Right, but that's the whole point of Money laundering.
B
That's the whole point of being a criminal. Right.
A
So let's talk a little bit about this. How many people have reported. Do we know how many people have reported gains for cryptocurrencies? I assume primarily Bitcoin in the last five years.
B
Let's say we don't know for sure, but the IRS did make a claim in a court pleading against Coinbase where they were trying to get their hands on some Coinbase records. But they said in that pleading that only 800 to 900 people paid gains on cryptocurrency between 2013 and 2015. That relates to about 14,000 people who had sold over $20,000 worth of cryptocurrencies just on Coinbase. Just on Coinbase, 800, 900 people had.
A
Paid taxes across the entire universe of cryptocurrencies within the United States or just.
B
Coinbase users across the United States, Total according to the irs.
A
Do we know what percentage of transactions or Bitcoin is stored on Coinbase for all Americans?
B
I don't believe we have that data, but due to the pseudo anonymous nature of this, there's no way to come up with those, at least currently, as far as I can tell, no one has come up with those types of statistics.
A
Except for there is that company. What's that? Chain analysis or something. We're going to get into that because the IRS is using that company to try and figure out who owns what and everything else, which is interesting, and I want to talk to you about that. Actually, a very small number of people have reported taxes on bitcoin and cryptocurrencies. The estimate is that there are many, many, many, many, many people who have realized gains in a cryptocurrency but haven't paid taxes either out of negligence, either out of just not knowing or whatever. There could be a gazillion reasons why I want to have this conversation. I should have said this in the beginning because I want to give the audience the most information possible. Something that I think is really important because whether you agree with being taxed on this or not, and I actually think there's some really ridiculous ideas. Gains in Bitcoin. Now we can get into some of the particulars that I think are most ridiculous, just for fun, but it doesn't matter. At the end of the day, you have to pay the irs, because if you don't, there are consequences. What constitutes a taxable event in the context of Bitcoin or in other cryptos?
B
Well, it depends on the situation. If you purchase cryptocurrency that is not a taxable event. It would be upon the sale of that cryptocurrency that would be the taxable event. Now, that's with buys and sells. It's a little different if you were to receive cryptocurrency for a service of some kind, let's say you perform a service or sell goods and receive cryptocurrency for that, that would be a taxable event in and of itself, and they're handled a little bit differently.
A
It's a taxable event only if there's a gain in the underlying value of the currency that I'm transacting in or that I'm cashing out of, right?
B
Well, no, let's say I performed accounting services for you and you pay me in cryptocurrency. My receipt of that cryptocurrency in and of itself, even though I haven't sold it, even though I haven't sold it, is still income to me because I did work and I got paid. So essentially, I would have to value that cryptocurrency in US Dollars, and that would be the amount that I would be required to report on my tax return.
A
So basically, whether I'm cashing out, whether I'm buying Bitcoin as a speculation for an appreciating value and I see it as an asset, or whether I've actually used it in transactions, which is less likely today because of the size of Bitcoin, most people tend to for that particular cryptocurrency. I think this is also interesting, right, because this brings us into a question about the difference between different types of tokens, right? Like if you have a utility token, like an Ethereum, where you're using it as part of, like a fuel, that kind of really puts an enormous burden on the network in terms of having to account for whatever value that token is at any moment in time. It dampens the utility value of that token, doesn't it?
B
Well, correct the way the tax laws are currently set up, having to report every single transaction, either a gain or a loss, is extremely burdensome from a reporting requirement. It takes a lot of work and takes a lot of record keeping. There's some potential for that to change at some point in the future. But as of right now, that is a big impediment to global acceptance of, at least in the United States, acceptance of cryptocurrency and using it for regular transactions.
A
That's not something that I've heard people talk about, and I think it's huge. Right. Like, so I know about this a bit just from the precious metals market. A lot of people assume that the legal tender laws are what prohibit or make it difficult for people to transact in a non U. S Based currency. But in fact it's the irs. In fact, it's actually having to pay taxes. You have to pay taxes in dollars. I think it's even heightened more so with utility tokens. Because if you're going to build a network where you're transacting in an underlying, you need something that's an underlying piece of fuel and you need to actually account for the appreciation of United States. If you're transacting in dollars and the dollar is in a bull market, a multi year bull market, let's say, and the dollar index is up 20% year over year, you don't need to pay taxes on that 20% rise in the US dollar because you're living in the United States.
B
Correct. You're in dollars the whole time.
A
Exactly. It's just an interesting thing. It's something that I've never thought about until you brought it up to me. It makes me wonder how to work all these things out. Again, this is a really specific example of how the regulatory dilemma is really problematic. Much more like Ethereum for a protocol for a distributed consensus network like Ethereum than it is for Bitcoin where it's a very simple kind of asset appreciation and you're buying and holding and selling.
B
One transaction at a time.
A
Exactly. But it really limits the case for using for the utility of the underlying currency. Talk to me a little bit about like exchange. I mentioned that in the beginning when I mentioned how I heard you, how I met you, and I was hearing you talk with a couple of Wall street guys about this. What is a like kind exchange, a 1031 exchange and how is that relev to this conversation around taxable events? Because many people, I think even people in our audience will have heard about this.
B
Yes. So a like kind exchange is an exchange of one type of property for another. And the two types of property need to be of what's called like kind. They need to be similar. And there's been some case law on that historically. Normally this is related to real estate and generally only real estate, but there's been a few other types of transactions that have occurred. So a like kind exchange is an exchange of one piece of property for another. If you exchange one piece of property for another, normally that would be a taxable event. The like kind exchange or 1031 exchange because it's IRS section 1031 allows you to defer recognition of that taxable event. So let's say I buy a piece of real estate for a million dollars. I trade it for another piece of real estate when they're both worth, say, 5 million. Instead of me reporting a $4 million gain, if I file the paperwork correctly, I can defer that gain and pay it at some point down the road when I sell my new piece of real estate.
A
Essentially what it allows you, it basically sees the two pieces of real estate is the same. You're able to make a transaction trading one piece for another, basically in your portfolio. And you can defer having to pay the taxes later on.
B
Yes. So there's three relevant issues. This is going away in 2018, only going away.
A
Does that have to be in the same market? Like, for example, does it have to be like, if I'm selling a piece of real estate in Miami, does one piece need to be on South Beach? Does the other piece need to be on South Beach?
B
No.
A
So I could sell my south beach property and buy something in Idaho.
B
Correct. Only caveat with that is you're not allowed to get. It's called constructive receipt of the fund. So if you sell your property, get money, and then buy a new piece of property, that's no good. What you'd have to normally do is use some kind of an escrow agent to keep that money out of your hands.
A
That's interesting, though, because there is a big difference there, because you are. I'll make my point as to why I'm thinking about that. But really, if I think that because real estate is local, south beach real estate is not the same thing as real estate in Idaho, if I'm going to be doing that, that could be very advantageous to me as a real estate buyer and seller, which you could easily make the argument for someone who's, let's say, trading Ethereum for Bitcoin.
B
Right. With regards to real estate. You're right. It's a fair point. Maybe a piece of real estate in Idaho is not like a piece of real estate on south beach. But for purposes of the tax law and the way this has gone so far, the government is going to accept to any, pretty much any two pieces of real estate. With regard to cryptocurrency, it's kind of unsettled. Real estate's a little different. There's a lot of case law in real estate, but with regards to, like, kind exchanges for other types of assets, it's kind of limited. They're not that common. What we do have some regulation on is precious metal exchanges, and I think that is probably the closest proxy to cryptocurrency. If you're going to look at past case law and revenue rulings. There was a court case in the 9th district of California where they found that gold coins traded for gold coins did not count as a like kind exchange because both of those coins were collector's items. You know, the two coins in question, one were Swiss francs, old Swiss francs, back when they used to be made of gold, and some other type of gold coins. They were rare items and they were priced based on their rarity. Whereas in other types of cases, the IRS has said in revenue ruling 7614 that an exchange of 50 Mexican peso gold bullion coins for Austrian Corona gold coins did qualify as a like kind exchange because those types of coins are simply valued based on their metal content. So you're trading basically raw gold for raw gold, even though it's in the shape of a coin.
A
Right. Well, I was saying to you when you told me this, I mean, I could see, first of all, it makes sense, the numismatic value difference. I mean, if I found gold from Columbus ship, one gold coin, one ounce of gold from Columbus ship, that's obviously going to be worth a ton more than some melted ounce of gold. I understand that, but I also think. I think it's interesting to point out that it's also true that thousand ounces of gold coins is worth more than a gold bar, because a gold bar is the same amount of gold. But there's a utility value to being able to transport those coins. I guess my point is that I can see the nuance in each one of these, and I'm pointing that out as we're talking. Go ahead. I'm sorry to interrupt.
B
Okay. I've spoken with some other people about this and the. There haven't been any tax rulings on this. So we don't know for sure whether a cryptocurrency can qualify for a like kind exchange at all or if they, you know, can very easily qualify. But the way it looks like to me, since the value of. With reference to the gold example I gave, what it comes down to is the nature and the character of that piece of property with regard to cryptocurrency. Here's the way I kind of see it. If you were to trade Bitcoin for, say, Bitcoin cash, those are very similar assets. A lot of their code is similar. They're both pure cryptocurrencies. They don't have any utility outside of being a cryptocurrency, something you can trade as a medium of exchange that is more likely to qualify as a like kind exchange than let's say, a trade of bitcoin for Ethereum. Because, as you know, Ethereum is a utility token. Ethereum is designed to be used as gas to basically run a transaction through the ethereum blockchain. So the value of Ethereum is impacted by different factors than the value of a bitcoin, whereas the value of a bitcoin and a value of the bitcoin cash are much more similar. So it's safe to say that the more alike your cryptocurrencies are that you're trading one for another, the more likely you would be to qualify for for this deferred gain.
A
Sounds like it's still pretty fuzzy. What about if I were holding 100 bitcoins during the hard fork and then I got 100 bitcoin cash?
B
Well, that's a little different. We're not in, like, kind exchange territory anymore. But there's actually two competing schools of thought on that as well. The first is pretty simple. The IRS says bitcoin is property, and it says that all cryptocurrencies are property. You had one type of property.
A
What ruling was that?
B
This was IRS notice 2014-21. They declared that any convertible virtual currency is to be treated as property. A lot of what I've been talking about today derives from that.
A
When was that? 2014.
B
It was March 25th of 2014.
A
2014. Go ahead. I interrupted. We were talking about the hard fork and the fact that you basically got a bunch of free bitcoin cash that have since appreciated in value.
B
Correct. One school of thought is that receiving the bitcoin cash is almost as though you had mined that bitcoin cash. You just got a new piece of property, and you have to pay taxes on that new piece of property right away. So I forget the exact value of bitcoin cash when it launched, but let's say it was $250, and let's say you held four bitcoin, you were given four bitcoin cash. That would be a $1,000.
A
So you only pay profits on what it was on the first trading day, at the close of the first trading day or something.
B
Right. Because that's when you received it.
A
That's a nightmare, Mark. Honest. This is a nightmare. No wonder you guys make so much money.
B
Yeah.
A
You have to help us. You have to help us. Go ahead.
B
So that would be when you Received it. You pay taxes when you received it, just like you mined it or just like you performed a service for it.
A
So are you saying that if I take my metal detector. Because I was a big fan of, like, I don't know. Did you have a metal detector growing up?
B
I did not.
A
I didn't actually have one, but, like, my uncle had one, and, like, we went once, like, looking for, like, you know, treasure.
B
Right.
A
I had a whole thing with him. I don't know where it came from. Maybe 80s movies. Yep. But you're saying that if I took my metal detector and I started, like, going, you know, to the bee, and I found some gold coin and I found $1,000 that I have to pay taxes on that to the US Government?
B
That's correct.
A
That's pretty crazy.
B
Found property would be pretty nuts.
A
Not intuitive. Even though I understand the logic, it doesn't seem intuitive that I'd have to pay if I found $20 on the street that I have to pay taxes on $20 anyway, legally speaking. So go ahead. I interrupted you again, Mark.
B
So that's one school of thought is that, hey, you just received a new piece of property, like a dividend, you need to pay taxes on it. Little different than a dividend because dividends can qualify for preferential tax treatment, whereas cryptocurrency.
A
To pay my income tax bracket, whatever it is, I have to pay that.
B
Correct. That's ordinary income to you on that date, basically. The second school of thought is that this type of transaction, this forked bitcoin cash, for example, is kind of similar to. Let's say you're a farmer and you have a cow and your cow gives birth to a calf. That is not and has never been considered a taxable event. So is bitcoin cash more like finding a piece of gold buried on the beach somewhere with your metal detector, or is it more like the bitcoin gave birth?
A
That's pretty amazing. That's really amazing. That farmers. I guess it would take a lot. I don't know how long it would take to grow your stock, your farm stock. But that's a pretty interesting idea that you can start with a certain number of calf and you can actually expand your asset base and not get taxed for it. That's interesting. That's a whole thing. I bet there's so many fascinating aspects of tax policy in the United States and somebody.
B
Not as many as you would think.
A
Come on. I bet there are. And I bet there are all these incredible loopholes that when you know how to Use them and exploit them. It is a very, very powerful tool.
B
Definitely it can be interesting.
A
That's why so many people have managed to make tons of money and pay very few taxes. And the rest of us are paying up the ass for Ferrari. I'll tell you anyway. All right, I'm going off the chains again. But there's just something really fun about having you here, Mark. Thank you. All right.
B
Okay.
A
So you're saying with regard to that, okay, it's either it's a tax, either it's property that you received, or it's a calf that was born from your bigger bull. Not bull. Bulls don't give birth from your cow, in which case you don't have to pay taxes on it. Correct.
B
Not clear taxes when you were to sell it.
A
But going back to the like kind Exchange, to the 1031. What we do know though, for sure is under the new tax bill, they have restricted 1031s to real estate assets only. Right?
B
Correct. The other important point to mention there is for a 1031 exchange, you need to be holding that piece of property for investment purposes, not for resale purposes. And again, this is another fuzzy area. The IRS has said with regard to real estate, if you hold a piece of real estate for over two years, they will consider that to be for investment purposes, at least two years. It's probably safe to say that same two year holding period would apply to Bitcoin or any cryptocurrency if you're holding it for a shorter period of time. It depends on the facts and circumstances of that particular case. If you hold it more than a year, the longer you hold it, the more likely it is to be an investment than being held for resale. But if I bought something as an investment, let's say I bought a piece of real estate for an investment, and I was going to hold it for a long time, I intended to, but then you come knock on my door and offer me a bundle of money for it. I can have that really big gain there. I can qualify for a 1031 if a court feels that in that circumstance I was holding it for investment purposes, but I just decided to sell it early. So it's very much a gray area.
A
That's interesting to clarify something going forward. It's very clear that like, you don't qualify for like kind exchange under any circumstances. Under any circumstance if you own or transact in any other cryptocurrencies. But it's not clear whether retroactively or prior to the passing of this new tax law that you qualify. And that's something that people would need to look at with their accountant, correct?
B
Yeah. The new tax law has not changed.
A
Anything because you may actually qualify. In other words, you may actually qualify in the past for a litecoin exchange. It's unclear and you should look into it.
B
Correct. Like I said.
A
But you don't think so. You don't think so. You think it's unlikely?
B
I'd say it's probably unlikely, yes. But again, the closer those two currencies are like say Bitcoin for Bitcoin cash. That's more likely than Bitcoin for Ethereum.
A
I want to ask you one more thing that has to do with how the IRS is tracking and keeping up with who is transacting what and at what valuations. You mentioned this one company called Chain Analysis, and they have a really interesting process for how they've been able to actually figure out who owns what. Now you explained this to me, but explain it again to me because I still am a little unclear on it and it'll be helpful for my audience to understand as well.
B
It's known, I've read in several articles that the IRS has a contract with. It's a company called Chainalysis.
A
Chainalysis.
B
Chainalysis, yeah, one word. And they've had that contract in place since 2015. And Chainalysis is a company that does basically big scale data analytics on blockchains. And I think they're probably mostly focusing on Bitcoin at this point because that's where the money is from a market cap standpoint. But that seems to be changing on a daily basis. But what Chainalysis does is they basically gather data on blockchain transactions. And what they're able to do is they're able to sometimes link different accounts. Like for example, if I'm holding Bitcoin, say I'm holding five Bitcoin, I could be holding those five Bitcoin in one account or I could have them spread out in several different Bitcoin addresses. Accounts, probably not the right word. The public addresses. Correct. Let's say I'm holding my five Bitcoin in two different accounts and I send five Bitcoin to you. Both accounts are going to be inputs to one transaction and that transaction is going to have one output to you. Chainalysis looks for those types of transactions and once they see one of those, they recognize, okay, these two accounts are linked. They must be owned by the same person because they would need to have the same password in order to make this transaction happen. They basically just monitor the blockchain on an ongoing basis, looking to form those types of relationships.
A
They're consolidating wallets. Basically, they're figuring out all the different accounts that you have, and they're figuring out what the one person is that has all those accounts. Correct, which makes the accounting process a lot easier.
B
They're also linking many transactions to known Bitcoin exchange accounts. So if Coinbase, if I want to send some money to Coinbase and they give me an address to send it to, that's known now that that address is a Coinbase address, so they're able to link that address to other addresses. And. And even if you didn't exchange directly with an exchange, you might be able to be linked to one through another person. If I were to buy Bitcoin on Coinbase and then sell it to you in a private transaction, if the IRS were to come after me and let's say they were to catch me in some type of tax evasion, they could then try and get me to flip on you if you're a bigger fish.
A
I kind of bring this up for one really big reason. One, I'm just always interested in creative ways that people do things. I think that's really interesting and creative that they're doing this. I wouldn't want them catching me. Good thing, like I said to our audience, that I haven't bought a single Bitcoin for other reasons. What I am most interested in pointing out is that this false narrative, this idea that you can evade taxes through Bitcoin, that a lot of people seem to think who don't own Bitcoin or don't transact in Bitcoin is completely false. Actually, the paper trail is it probably makes it a lot easier to catch somebody, which is what everyone says, what certain people point out. Let me ask you one last question, Mark. Let's say we're getting near tax season. What would you not advise people? Is any accountant able to do this? Are there certain accountants that are more qualified? Also, how can people reach out to you if they have a question or something like that?
B
I'd say definitely. I've talked to a lot of different accountants. Some know this, understand it, and some just don't. As long as they're up to date. And reading that IRS revenue ruling, how.
A
Many understand this, Mark?
B
Yeah, it's not that many, actually.
A
There are not really that many, dude.
B
I see just a handful of them at these networking events here and there. But you're right, there's not that many. But if you do want to reach out to me, I can give my contact information here. Yeah, do that. It's 212-697-1000, and I'm at extension 1369.
A
Do you want to give out your email, too, or something like that?
B
Is there a way we can just post it on the website?
A
Yeah, I'll do that. I mean, people listen. Not everyone goes to. I mean, hardly anyone goes to the website, but.
B
All right, then let's. We'll keep it on the.
A
Okay. And you're a great guy, which is why I actually wanted. Not only are you smart and you're into this stuff, but you are a really good person. If I did have anyone doing my taxes, I'd feel very comfortable with you doing it. So I appreciate you coming on, and I hope our audience has learned something important from this very hazy and emotional subject.
B
Great. Thanks for having me.
A
All right. Thanks.
B
I appreciate it.
A
And that was my episode with Mark Demichel. I want to thank Mark for being on my program. Today's episode was produced by me and edited by Stylianos Nicolaou. For more episodes, you can check out our website@hiddenforcespod.com Join the conversation through Facebook, Twitter and Instagram Iddenforces Pod. Or send me an email at dk@hiddenforcespod.com. thanks for listening. We'll see you next week.
Host: Demetri Kofinas
Guest: Mark Demichel, Forensic Accountant, Citrin Cooperman
Date: January 15, 2018
This episode dives into the murky and rapidly developing world of cryptocurrency taxation in the US. Host Demetri Kofinas talks to forensic accountant Mark Demichel about what constitutes a taxable event with Bitcoin and other cryptocurrencies, the latest IRS rulings, loopholes, reporting requirements, the Like-Kind Exchange debate, and the real-world implications for anyone who has profited from or transacted in crypto. The discussion offers practical insights, explores legal gray areas, and unpacks the unique challenges posed by decentralized digital assets.
“Florida subsequently passed legislation saying for purposes of money laundering, this stuff counts.” – Mark Demichel (03:27)
IRS data from court filings against Coinbase: only ~800–900 people reported gains on crypto between 2013 and 2015, despite over 14,000 Coinbase users selling >$20,000 of crypto (04:40).
“800, 900 people had paid taxes across the entire universe of cryptocurrencies.” – Mark Demichel (05:10)
There’s no public data on the total number of Americans with Coinbase-held Bitcoin, largely due to Bitcoin’s pseudonymous nature (05:25).
“My receipt of that cryptocurrency in and of itself... is still income to me because I did work and I got paid.” – Mark Demichel (07:10)
“Having to report every single transaction... is extremely burdensome from a reporting requirement.” – Mark Demichel (08:14)
“With regards to like-kind exchanges for other types of assets, it’s kind of limited. What we do have some regulation on is precious metal exchanges.” – Mark Demichel (12:32)
“Is bitcoin cash more like finding a piece of gold buried on the beach somewhere... or is it more like the bitcoin gave birth?” – Demetri Kofinas (19:27)
“They basically just monitor the blockchain on an ongoing basis, looking to form those types of relationships.” – Mark Demichel (24:38)
“I've talked to a lot of different accountants. Some understand this, some just don’t...” – Mark Demichel (26:33)
On the complexity of reporting every crypto transaction:
“Having to report every single transaction, either a gain or a loss, is extremely burdensome.” – Mark Demichel (08:14)
On IRS’s recognition of Bitcoin as property:
“They declared that any convertible virtual currency is to be treated as property. A lot of what I've been talking about today derives from that.” – Mark Demichel (16:49)
On using Chainalysis for blockchain surveillance:
“They basically just monitor the blockchain on an ongoing basis, looking to form those types of relationships.” – Mark Demichel (24:38)
On old misconceptions about crypto and tax:
“This false narrative, this idea that you can evade taxes through Bitcoin... is completely false.” – Demetri Kofinas (25:34)
On how few accountants “get” crypto tax rules:
“I see just a handful of them at these networking events here and there, but you’re right, there’s not that many.” – Mark Demichel (26:47)
The host’s tone remains skeptical and curious, infusing the discussion with humor and candid frustration about tax complexity:
“This is a nightmare, Mark. Honest. This is a nightmare. No wonder you guys make so much money!” – Demetri Kofinas (17:46)
Contact Info:
Mark Demichel can be reached at Citrin Cooperman: 212-697-1000, ext. 1369. Email is available on the Hidden Forces website.
For further information, check out other episodes at hiddenforcespod.com.