# kaal:claim:3002908-013

**Claim.** The IRS confined its virtual currency position to transactions in convertible virtual currency, which leaves the tax treatment of crypto limited partnership interests unaddressed.

**Type.** failure  **Support.** argued

**Holds when.**

- under 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, Marco Dell'Erba, *Blockchain Innovation in Private Investment Funds - A Comparative Analysis of the United States and* (2017), III.2. United States, page 18

**Cite as.** Wulf A. Kaal, Marco Dell'Erba, Blockchain Innovation in Private Investment Funds - A Comparative Analysis of the United States and (2017). SSRN: https://ssrn.com/abstract=3002908

**Verify.** sha256 of source PDF `06a7b61e75f905ee07e422e875d83a65c5033a248a6e05a213523b034e5db534` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20and%20Dell%27Erba%20-%202017%20-%20Blockchain%20Innovation%20in%20Private%20Investment%20Funds%20-%20A%20Comparative%20Analysis%20of%20the%20United%20States%20and.pdf

**Failure mode.** tax-guidance-gap  (family: regulatory-lag)

**Topics.** private-funds

**Keywords.** irs, taxation, virtual-currency, private-funds

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