Crikey, this point is so incredibly obvious I feel stupid to have missed it, but wouldn't a hard fork be a CGT disposal in the UK, on general principles?https://twitter.com/Omri_Marian/status/975847726972747776 …
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Replying to @DanNeidle
I know next to nothing about UK CGT, but shouldn't there be a "disposition"? Theoretically you dispose of nothing at the time of the fork. It's just that one day, one coin becomes two coins.
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Replying to @Omri_Marian @DanNeidle
Yes but you have disposed of/realised (theoretically) part of your first asset for the new coin. Taxable in Aus; specific CGT to catch receipt of rights; not taxable in CH unless trading ;)
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Replying to @p_sfitz @DanNeidle
Why? You get to keep the original coin. You don't exchange one for the other. You keep both. It's more like a split.
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Replying to @Omri_Marian @p_sfitz
I confess I have not thought about it for more than 5 seconds, and I could be wrong, but I expect the new coin is a "capital sum derived from an asset", and hence a taxable gain under s22(1). "capital sum" includes "money's worth", i.e. stuff convertible into cash.
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Given HMRC still have guidance up suggesting Bitcoin profits might amount to (non-taxable) gaming, they may not be entirely on this point. However - obvious caveat - anyone reading for whom this point is relevant should take independent advice. This is not advice.
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I once thought it akin to a stock split but where there is independent market value of the coin you get for free (eg bitcoin cash), it seems hard to argue that you don’t have income.
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