Bloomsbury Professional Tax Insight: Cryptocurrency and Blockchain

1 Introduction
2 What is virtual currency?
2.1 Definition of Financial Action Task Force
2.2 How is bitcoin different to earlier virtual currencies?
2.3 How is the cryptocurrency market evolving?
3 How does bitcoin software work?
4 Further applications of blockchain technology
4.1 Brief overview of the state of blockchain
4.2 Utility tokens
4.3 Security tokens
4.4 Smart Contracts
5 Income Tax
5.1 Cryptocurrency purchases and sales - Is the taxpayer conducting a “trade”?
5.2 Tax implications if a “trade” is being conducted / treatment of losses
5.3 Mining of cryptocurrency
5.4 Airdrops – tax treatment
6 Capital gains tax
6.1 Introduction – applies to most individuals
6.2 What constitutes a disposal of cryptocurrency?
6.3 What are the allowable costs?
6.4 Valuation of cryptocurrency assets – conversion from a foreign currency
6.5 Pooling rules
6.5.1 General pooling rule
6.5.2 Purchase and sale on the same day
6.5.3 30 day-rule
6.6 Blockchain forks – creation of new assets
6.7 Airdrops
6.8 Capital losses
6.9 Losing a private key – crystalising a capital loss?
6.10 Fraud
7 Cryptoassets received as employment income
7.1 Cryptoassets provided in the form of Readily Convertible Assets (“RSA's”)
7.2 Cyrptoassets which are not in the form of RSA's
7.3 Cryptoassets provided by third parties
8 International aspects – non-resident investors
8.1 Non-resident investors “trading” in cryptoassets
8.2 Non-resident investors realising capital gains from the sale of cryptoassets
9 International aspects – offshore cryptocurrency funds
9.1 When will a cryptocurrency fund be subject to the UK offshore fund regime?
9.2 UK investor manager exemption
9.3 Importance of establishing that the fund is tax resident in the jurisdiction in which it is incorporated