1/ How U.S. Tax Changes Could Reshape Crypto The Trump admin is preparing a broad overhaul of crypto taxation. Treasury and a White House working group are floating rules that would touch nearly every corner of the crypto ecosystem, from staking and cross-chain "wrapping" to corporate minimum-tax treatment relief, mutual-fund and 401(k) eligibility, asset-class definitions and even whether stablecoins should be treated as debt. The combined effect could be sweeping: wider access for investors, heavier reporting burdens for platforms, and the first coherent tax framework for the industry.

2/ Emerging Crypto Tax Landscape In July, the Digital Assets Working Group rolled out a broad policy blueprint for crypto, followed in Sept by the Treasury's Priority Guidance Plan, which signaled forthcoming rules across a wide range of issues. Until now, official guidance has been thin: a 2014 IRS notice treating virtual currency as property, a 2019 ruling on hard forks and airdrops, and the 2021 infrastructure law's broker-reporting rules. But nearly everything that now defines the crypto market--DeFi yields, wrapped tokens, cross-chain bridges, stablecoins, tokenized funds, L2 assets, liquidity pools and institutional custody--still sits entirely outside U.S. tax law.

3/ Opening Mutual Funds to Crypto The IRS and Treasury's Guidance Plan proposes treating digital assets as "qualifying income" for mutual funds, a key step toward opening retirement plans to crypto. To retain regulated investment company status, at least 90% of a mutual fund's income must come from qualifying sources, and crypto isn't one yet. More than 60% of 401(k) assets sit in mutual funds, so this change could bring digital assets into Americans' retirement portfolios. Recognizing crypto as qualifying income would allowe asset managers to include modest exposure inside diversified funds, expanding access without jeopardizing a fund’s tax status.

4/ IRS Staking Rules Platforms offering crypto staking could face short-term pressure if the IRS clarifies how rewards are taxed, though clearer rules could boost participation. Current guidance is limited: The IRS' 2023 Virtual Currency Transactions FAQ states that staking rewards are ordinary income when received. Key questions remain about the timing of income recognition, character of the income, source rules and how exempt investors are treated.

5/ Relief from Corporate Alternative Minimum Tax (CAMT) The administration's July report on digital finance calls for exempting crypto from CAMT, arguing that the tax's book-income base can capture unrealized gains in highly volatile digital assets. The report recommends aligning CAMT with income-tax principles so companies would be taxed only when crypto is sold or exchanged. Consider Strategy: In Q1-25, its BTC cost basis was about $35.6B vs $43.5B market value, an implied $8B gain that could inflate CAMT liability. In Sept, Treasury’s interim guidance said unrealized crypto gains won’t count for the tax. But this is an interim policy, not statutory. Without legislation, guidance can shift and leave companies exposed.

6/ Wrapped Tokens Tax Implications for Interoperabilty Custodians along with validators "wrap" assets so they can move across blockchains. Market practice generally treats wraps that create a new token as taxable and pure representations as non-taxable (same asset, new chain). But there's no clear legal basis for this split. Notice 2014-21 broadly treats any token usable across multiple blockchains as taxable property. If all wrapping were taxable, cross-chain activity could plunge and U.S. users could migrate to single-chain or custodial setups to avoid constant realizations. This could result in re-centralization, undermining the multichain architecture that supports much of today’s crypto market.

7/ Securities, Commodities or Something Else Crypto is treated as property for tax purposes, but it's unclear whether digital assets also qualify as securities, commodities or something else entirely. That classification matters for tax provisions: mark-to-market elections apply only to securities dealers and traders, the Section 864(b) offshore trading safe harbor covers only securities and commodities, partnership rules treat some commodity income as "good" but restrict security income and securities lending, and wash-sale rules apply solely to securities. It's not clear how digital assets are treated under any of these rules or whether they apply at all. The administration's report proposes defining crypto as its own asset class, applying these provisions distinctly. The lack of clarity makes digital assets less fungible and adds uncertainty to tax treatment.

8/ Are Stablecoins Debt? The administration's report suggests classifying stablecoins as debt, or as instruments akin to money-market funds. Payments, swaps and redemptions would be non-recognition events, and users wouldn't need to track basis except when a coin trades at a discount or premium. Issuers would face heavier burdens--interest accounting, withholding and Form 1099-INT reporting--shifting compliance from users to issuers. Today, stablecoins are treated as property, meaning minimal issuer tax obligations but high user friction: each spend, swap or redemption is a taxable disposition and even tiny price moves trigger tax and reporting. Treating them as debt would make them function more like commercial paper or cash, in practice. H/t @Argentuomo for the BI report on this