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Notice 2014-21 provides that convertible virtual currency is treated as property

Internal Revenue Bulletin 2023-19 · 2026-10-03 edition · updated 2026-10-04 · United States

for federal tax purposes and that general tax principles applicable to property transactions apply to transactions using convertible virtual currency. The Background section of Notice 2014-21 defines virtual currency as a digital representation of value that functions as a medium of exchange, a unit of account, and/or a store of value. The Background section also states that virtual currency does not have legal tender status in any jurisdiction. Rev. Rul. 2019-24, 2019-44 I.R.B. 1004, subsequently clarified that virtual currency does not include a representation of the United States dollar or a foreign currency.

The Background section of Notice 2014-21 describes convertible virtual currency as virtual currency that has an equivalent value in real currency, or that acts as a substitute for real currency. The Background section of the Notice also identifies Bitcoin as an example of a convertible virtual currency and explains that Bitcoin can be digitally traded between users and can be purchased for, or exchanged into, U.S. dollars, Euros, and other real or virtual currencies.

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