Certain Pre-2018 Cryptocurrency Exchanges Don’t Qualify for Sec 1031 Treatment – According to a Chief Counsel Advice, if completed prior to January 1, 2018,
an exchange of (i) Bitcoin for Ether, (ii) Bitcoin for Litecoin, or (iii) Ether
for Litecoin does not qualify as a like-kind exchange under § 1031. The CCA
concluded these cryptocurrencies were not of like kind. This CCA does not
address any other cryptocurrencies, or any other analyses not discussed in the
advice, so no inferences should be made based on this CCA that are not
explicitly set forth in this advice. Further, this CCA may not be used or cited
as precedent. (CCA 202124008)