Recent IRS Guidance on Bitcoin and Other Virtual Currencies

Level: Intermediate
Runtime: 91 minutes
Recorded Date: April 07, 2020
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  • Brief History on IRS Guidance on Bitcoin
  • Revenue Ruling 2019-24
  • Holding
  • Assumptions
  • Valuation
  • Dominion and Control
  • Wallet Providers
  • Phantom Income
  • Virtual Currency FAQ's
  • Conclusion and What's Next?
Runtime: 1 hour, 31 minutes
Recorded: April 7, 2020


On October 9th, 2019 the IRS issued Revenue Ruling 2019-24 which addressed the tax consequences of forks and airdrops as well as a series of FAQ’s that cover a number of common virtual currency situations.

This panel will go through the nuts and bolts application of the October guidance, how to advise taxpayers that previously took a position contrary to the guidance, and the inherent limitations of releasing guidance by FAQ.

The panel will also address some of the uncertainties of forks that still exist post R.R. 2019-24 and what future guidance is needed for virtual currencies.

This program was recorded on April 7th, 2020.

Provided By

American Bar Association


Christopher Wrobel

Special Counsel to the Associate Chief Counsel
IRS Office of Chief Counsel

Christopher provides legal guidance to the Associate Chief Counsel (Income Tax & Accounting) (“IT&A”) in the IRS National Office in matters pertaining to regulatory and other IRS published guidance projects within IT&A’s jurisdiction. Prior to joining IT&A in 2014, Christopher served for eight years as an attorney with the IRS Office of Division Counsel (Large Business & International) in Washington, DC, where he was responsible for litigation and providing legal advice to the IRS during examinations of large taxpayers. In addition to his experience with the IRS Office of Chief Counsel, Christopher served as a law clerk to the Honorable Susan G. Braden of the United States Court of Federal Claims, and as an attorney at a Washington, DC law firm.

James Creech

The Law Offices of James Creech

James Creech has been a tax attorney for a decade. During that time he has have saved my clients many millions of dollars in tax due. James prides himself on taking on difficult cases and getting great results for his clients.

James is a frequent speaker on tax topics. He often presents to other attorneys and CPA’s about the tax laws. He is active with the American Bar Association, the Illinois State Bar Association, and the California State Bar Association. James enjoys working with entrepreneurs and small business people.

Rochelle Hodes

Crowe LLP

Rochelle Hodes is a Principal in the Washington National Tax Office at Crowe. She has over twenty-nine years of experience providing tax controversy and tax policy services. Rochelle provides deep expertise in federal tax policy, including litigation, legislation, and regulatory proposals.

Rochelle specializes in U.S. federal tax practice and procedure, including resolution of federal tax controversies and compliance with federal tax laws. Her experience includes overseeing implementation of internal policies and procedures and oversight of tax return preparers and advisors regarding compliance with federal and state tax law.

Annette Nellen

San Jose State University

Annette Nellen, CPA, CGMA, Esq., is a professor in and director of San José State University's graduate tax program (MST), teaching courses in tax research, accounting methods, property transactions, employment tax, ethics, leadership, and tax policy.

Annette is a past chair of the AICPA Tax Executive Committee (Oct. 2016 to May 2019). She is a past chair of the AICPA Individual Taxation Technical Resource Panel. Annette was the lead author of the AICPA tax policy concept statement #1, Guiding Principles of Good Tax Policy: A Framework for Evaluating Tax Proposals (2001, 2017), still in use today. Annette is the recipient of the 2013 Arthur J. Dixon Memorial Award given by the Tax Division of the AICPA, the highest award given by the accounting profession in the area of taxation. In fall 2013, Annette completed a three-year term on the Executive Committee of the Taxation Section of the California Bar. and the 2019 Benjamin F. Miller Award from the Taxation Section of the California Lawyers Association for achievement and contribution in the field of state and local taxation law. Annette is a former chair of the ABA Tax Section’s Sales, Exchanges & Basis Committee. She is a member (and past co-chair) of the CalCPA Accounting Education Committee.

Annette is the author of Bloomberg BNA Tax Portfolio #533, Amortization of Intangibles. She is an editor for two of the Southwestern Federal Taxation textbooks. She is a monthly columnist (Moving Forward?) for Tax Analysts’ State Tax Notes.

Annette has testified before the House Ways & Means Committee, Senate Finance Committee, California Assembly Revenue & Taxation Committee, and tax reform commissions and committees on various aspects of federal and state tax reform. In 2000, Annette served on the academic panel that advised the Joint Committee on Taxation staff for the tax law simplification study submitted to Congress in 2001. In 2015 she was appointed to the California Board of Equalization Executive Director’s Advisory Council (now serving on the CDTFA Advisory Board).

Annette maintains the 21st Century Taxation website and blog (, as well as several websites on tax reform, state tax nexus, e-commerce taxation, worker classification, virtual currency taxation, and tax and ethical issues for marijuana businesses and tax advisers.

At SJSU, Annette is a recipient of the Outstanding Professor Award (2000/2001) and Distinguished Service Award (2004/2005).

Annette is a graduate of CSU Northridge (BS Accounting), Pepperdine (MBA), and Loyola Law School (JD). Prior to joining SJSU in 1990, Annette was with Ernst & Young and the IRS (revenue agent and lead instructor).

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