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Notice 2014-21 in 2026: Why It Still Controls Digital-Asset Tax Treatment

by Noah Green CPA CFE | Apr 28, 2026 | Sheepdog Tax Digital Asset Tax Notes

Notice 2014-21, published on March 25, 2014, is the foundational IRS guidance on digital-asset taxation. The Notice answered sixteen questions about the federal-tax treatment of “virtual currency” in a format that has not been formally updated in the...

Ordinary vs Capital: When Each Applies to Digital-Asset Transactions

by Noah Green CPA CFE | Apr 21, 2026 | Sheepdog Tax Digital Asset Tax Notes

Character classification, ordinary versus capital, controls the rate at which digital-asset income is taxed under IRC §1(h) and §1, determines which net-loss limitations apply under IRC §1211, and triggers the §1411 net investment income tax on most capital-gain...

Token-to-Token Swap as a Realization Event: IRC §1001 in Practice

by Noah Green CPA CFE | Apr 14, 2026 | Sheepdog Tax Digital Asset Tax Notes

A taxpayer who exchanges one digital asset for another, ETH for USDC on a centralized exchange, ETH for cbETH on a liquid-staking protocol, USDC for DAI through a decentralized exchange, or any of the dozens of similar transactions a typical wallet executes in a year,...

Wallet-Level Basis Under Rev. Proc. 2024-28: What Changed and What to Track Starting 2025

by Noah Green CPA CFE | Apr 7, 2026 | Sheepdog Tax Digital Asset Tax Notes

Rev. Proc. 2024-28 changes how digital-asset basis must be tracked for any taxpayer with units acquired in more than one wallet, exchange account, or custodial location. Starting January 1, 2025, basis is tracked wallet-by-wallet, not pooled across the...

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