Document Type
Comment
Abstract
This comment examines the challenges current federal tax policy faces in addressing the rapidly expanding and volatile digital asset market. The author argues that the Internal Revenue Service’s (IRS) current "piecemeal" approach to defining taxable events—such as mining and staking—creates significant uncertainty for taxpayers and leads to strategic litigation. To resolve these issues, the article proposes the adoption of Unliquidated Tax Reserve Accounts (ULTRAs) as an alternative reporting framework. By utilizing blockchain's inherent capability to track notional interests, ULTRAs allow the IRS to account for economic activity while offering taxpayers the flexibility to defer actual payment until the assets are realized. Ultimately, Liedel contends that transitioning to this model would stabilize the digital financial market, reduce administrative burdens, and ensure a more coherent application of the realization requirement in the digital age. +4
First Page
79
Last Page
111
Recommended Citation
Lauren Liedel,
ULTRAS: RETHINKING TAX POLICY FOR DIGITAL ASSETS,
19 J. Bus. Entrepreneurship & L.
79
(2026)
Available at: https://digitalcommons.pepperdine.edu/jbel/vol19/iss1/3
Included in
Administrative Law Commons, Banking and Finance Law Commons, Finance and Financial Management Commons, Science and Technology Law Commons, Taxation Commons, Tax Law Commons
