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On April 9, 2021, the Internal Revenue Service (Service) released Chief Counsel Advice 202114020 (the Guidance) regarding the tax consequences to an individual in receipt of Bitcoin Cash (BCH) following the August 2017 hard fork of Bitcoin (BTC).
1 In the Guidance, the Service largely reaffirms its historic position regarding the treatment of cryptocurrencies as property, and the tax treatment of new cryptocurrencies actively or constructively received by taxpayers after a hard fork that creates the new cryptocurrencies. The Service’s position was previously provided in Rev. Rul. 2019-24 (the Revenue Ruling), in which the Service ruled a holder of cryptocurrency that experienced a hard fork that created a new currency followed by an airdrop of that new currency had taxable income equal to the value of the new currency received. In contrast a taxpayer that did not receive units of the new cryptocurrency did not have inc