# kaal:claim:2998033-016

**Claim.** The IRS position that virtual currency is taxed as property is expressly limited to convertible virtual currency, which leaves the tax treatment of crypto limited partnership interests unaddressed.

**Type.** empirical  **Support.** evidenced

**Holds when.**

- based on IRS Notice 2014-21

**Source quote.**

> However, the IRS was very specific about limiting its current position to transactions involving "convertible virtual currency," leaving the tax treatment of crypto-limited partnership interests unaddressed.

**From.** Wulf A. Kaal, *Blockchain Innovation for Private Investment Funds* (2017), II.5. Regulatory Implications, page 17

**Cite as.** Wulf A. Kaal, Blockchain Innovation for Private Investment Funds (2017). SSRN: https://ssrn.com/abstract=2998033

**Verify.** sha256 of source PDF `aafb1be3c25cd33da477d759df9ca2f856f0a8fe133d6396da2e75d0af573dbd` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20-%202017%20-%20Blockchain%20Innovation%20for%20Private%20Investment%20Funds.pdf

**Topics.** institutional-design

**Keywords.** irs, taxation, virtual-currency, crypto-limited-partnership

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