Tony Billings and Santanu Mitra accepted for publication in Tax Notes

Mike Ilitch School of Business Professors of Accounting Tony Billings and Santanu Mitra have had an article accepted for publication in Tax Notes, which is a portfolio of publications with a large readership of practitioners, academics and policymakers alike.

The article, “Taxation of Cryptocurrency Transactions: Consequences of Hard Forks, Soft Forks, and Airdrops,” was co-authored by Kyungjin Kim, a former Ilitch School graduate student.


This article updates Certified Public Accountants (CPAs) and other financial professionals about recent changes in tax provisions by the Internal Revenue Service (IRS), along with other changes in guidance from other nation-states, to help financial professionals comply with revenue laws applicable to cryptocurrency transactions. In 2021, approximately $6.10 billion worth of cryptocurrency transactions happened globally, representing a whopping 177 percent increase from year 2020 levels. To address the international acceptance of cryptocurrency as legal tender, the IRS released several documents as guidance to taxpayers, including (1) IRS Notice 2014-21, (2) Rev. Rul. 2019-24, (3) Chief Counsel Advice (CCA) 202114020, and (4) IRS Legal Memorandum 202124008. A key determination of the new IRS guidance is whether a taxpayer has realized wealth enough to trigger taxation of the new wealth acquired. The article evaluates the taxable status of “hard/soft forks” and “airdrops” enumerated in Revenue Ruling 2019-24. In addition, the article reviews the various IRS releases and other nation-states’ provisions to aid taxpayers in complying with the new promulgations.

View all news stories