Optimiser votre stratégie fiscale pour le minage de Bitcoin | Bitcoin 2026

Hey, thanks for having us. All right, we are going to talk about taxation considerations for Bitcoin. Now, to be clear, there's not a ton of rules out there on point. So, we're going to talk about what what people are doing, how do you handle it. We're going to go through a bit of a life cycle, how to get started, what that entails, how to think about it, as well as operations, mining, obviously, some yield generation, dispositions for those who don't hodddle out there, and then some other futuristic views. So, some background, my name is Rob Massie. I'm a tax partner at Deote. Spend all my time in crypto. Have done that since 2012. We have a big team at Deote. There's 2,000 people across all the functions, many of which are here. Come see us in the enterprise hall, and I'm looking forward to bringing some insights. So, next up, Danny from Sorry. Yeah, go ahead, Danny. >> Uh, I'm Danny Condan. I am chief revenue officer at Blockware. We are a Bitcoin mining as a service company. So, we uh enable Bitcoin mining opportunities for individuals and institutions. >> Jeffrey? Yep. I'm Jeffrey Lee from FinTech. So at FinTech what we do we at the compli we are doing the compliance field we're helping companies do their accounting system helping them to reconcile onchain to offchain also we are helping a lot of international company that help set up company around the world so today I might able to bring up a lot of you from outside of United States >> so so the lenses we're putting on this you have the operator standpoint those helping you from an infrastructure standpoint actually stand it up what to think about There you've got a subleddger component. Critically important because the data elements we're gathering have to land in reports and considerations with tax in mind. And then we're going to talk about different jurisdictions throughout. So let's get started. Danny, when people are getting started, what are they doing? What are they inspired by? Just how to how to get things started and maybe some emphasis on the hardware element first. >> Yeah, maybe um let's talk about the business opportunity that that is Bitcoin mining. So, I'll take it kind of from that lens and I'll break it down into three buckets. So, why would you mine Bitcoin? Why should you mine Bitcoin from a business opportunity perspective? When you're mining Bitcoin, the the first bucket is you're generating free cash flow, right? So, businesses are designed to generate profit. So, you can go on an exchange and you can purchase Bitcoin around $77,000 of Bitcoin or you can mine Bitcoin where the objective is to be accumulating Bitcoin. I like to think about it as constantly dollar cost averaging Bitcoin at a discount to the spot price of Bitcoin. So the spread between my revenue which is Bitcoin denominated and my cost which is primar primarily electricity is my profit right the second bucket as a byproduct of the first bucket is that you're inherently building a Bitcoin treasury right and there's a lot of considerations on that front you can hold it you can sell it you can lend against it to generate uh incremental liquidity and then the third which will be I'm sure a primary focus of this discussion is that there are significant tax advantages, tax efficiencies, tax incentives associated with Bitcoin mining. And just real briefly, that's most recently on the back of uh the big beautiful bill which was passed last summer which brought back 100% year 1 bonus depreciation. Right? And what that means in in short is 100% of the capex that you uh put forth in in purchasing AS6 may be eligible for 100% year1 bonus depreciation. Very simple example, and I'm on stage with a CPA, so keep me in line here. Uh but if you spend $100,000 on A6, you may be eligible to reduce your uh ordinary income tax liability by $100,000. So I like to think about it as a mechanism for pay less taxes and instead put those funds towards a productive asset that generates Bitcoin. So when we're talking about Bitcoin mining and Danny's highlighting important point, many would choose to buy their own hardware. And when you have then there's a there's a physical element to this which we don't always think about with crypto. With Bitcoin mining, there's hardware somewhere. There's machines, there's AS6. And that means that there's a physical location somewhere in the world that you're mining. To Danny's point, you need to think about are you going to expense that right away in the US? Those rules do differ around the world, which we can talk about with Jeffrey in a minute. But where that exists is really important. It's not just federal taxation, but also state taxation. And where you put that hardware is going to govern where that taxation might occur, where the humans that then run the software. That could be in the US, it could be somewhere else around the world. So when you're setting up a mining operation, whether it's a small operation or a big one, you need to think about where it exists. What are the roles of those operations? critically important as we get to these other elements as well as thinking about you know procuring hardware you've got sales tax considerations you've got VAT around the world you have customs and duties and so you got to layer on all the components but it's really important as to where it exists so Jeffrey do you want to elaborate on the on the global component of this >> yep when we we have helped a lot of clients that set up around the world just like Rob is saying that outside of United States you have to consider about VAT which we don't have here and and depreciation we have very good case here we got 100% accelerated depreciation but outside is different and then customized uh custom or import duty it is something that we should consider uh I have a few example few case that we set up so like in Canada just north of our neighbor right so they also have a salelary depreciation but not as good as here it's 27.5 on the first year and then remaining balance is at 55% each year afterwards so it's accelerated but not the same but they have a VAT system. So you actually have to take consideration about the VAT the import uh input tax credit that whether or not you're able to claim back and then they have special rules about it you have to look into and last but not least is the import credit they don't have it contrast that to UAE where also set up those three taxes also similar but um depreciation wise they don't have a salelerated it's different but their corporate tax is quite low it's only 9%. So in a sense your depreciation is not costing that much on your profit level. And then they have very simple VAT structure. It's only 5% no import tax. So that is a place that is a world that is have very simple tax scheme. And then there's another place that we set up is Kakascent where it has very low electricity bills. Why people want to go there? Because it's very low electricity bill but their tax structure is much more complicated. They have a import duty tax is more than 5%. you have VAT more than 10%. So at front when you set up the whole thing, you already have additional cost to it. Nonetheless, they have very interesting add-on tax onto their electricity. So for every one megawatt uh kilowatt that you're using, you actually have to pay more uh 0.2 cents to 5 cents depending how much you're using it. So in a in general when you look at the whole world you have to start planning where you set up the things and actually look into the detail as to how the VAT how the depreciation how the import tax or any add-on tax works in order to have the best schema for your company and it it's very common for us to be thinking about mining operations in different jurisdictions. You might have a management team and a parent company in one jurisdiction one country you may have mining operations with machines in another. you actually have to put the tax lens on every different jurisdiction to think about this stuff and then how it rolls up which is you know something that we don't always think about but because we have hardware involved there's special considerations so Jeffrey you started getting into the operational components and and and electricity I want Danny maybe you take that a step further because as that this tends to be one of the bigger expenditures out there now is going to be power so bring us into that world >> yeah so let's talk about and for context I'm looking at this through the lens of like a capital efficient uh hosted mining operation. That's what Blockwork does, right? So, we work with individuals and institutions to enable folks to get access to mine Bitcoin without having to turn screws in a data center, so on and so forth. So, again, to qualify it, the revenue side of this is when you're mining Bitcoin, your revenue is Bitcoin, right? And then you have a cost side associated with that. in and in in a block we're example like 99% of your cost is uh the cost of electricity that that those AS6 consume right so we have one component of this is the capex on the hardware which again domestically 100% year one bonus depreciation I talked about that now think about it on the operating side of the business I have you know a a reasonably fixed cost side of electricity and then the revenue side is going to be variable. So I think maybe a lead into this provides a lot of interesting kind of treasury strategies because as a you know client your obligation is to pay your energy bill right and that can be in dollars you know fiat outside of you know funded separately. It can be with a portion of your, you know, bitcoin revenue and you just, you know, hold or do what you'd like in your treasury with the, you know, with the profit, right? So, but by and large, 99% of the cost is fixed in energy. Something to remember, we're talking about deductions here. Deductions are only allowed, and this is a heavy US lens, but also abroad, only if you have a trade or business, right? When people are just like mining for fun, you might think about, you know, is is there even a business there? Is it a hobby? What is it? If you're not, you need to think about what is your business? Are you generating revenue? If you're huddling and you're not selling anything, you may get a question later from the IRS. Do you really have a trader business? Are you just accumulating Bitcoin? This is a really important question. And so, keep in mind that the tax deductions in the US, again, thematically abroad, only if you have a trader business are you allowed those deductions can you recover those costs. So, just keep that in mind. These are basic principles but you got to you got to start with that. Jeffrey take us now and let's go outside the US and what are some of the operational considerations there. >> So in terms of operation consideration just like Rob say if you have a trade or business around the world operations expenses are deductible on on your income statement and then when you calculate tax but there's finer details as to each tax rules around the world. Let's say for Canada, they have the VAT system where you have import uh input tax into your system where you buy electricity, they will charge you GST. Normally, if for any trade or business, you can claim that GST as part of your input tax credit. But in Canada, there's a special rules for mining. You actually cannot consider or it is called GST exempt. When you think exempt, it's a good words, right? You're not playing yet. No, in this course, it's actually worse. you're not able to claim the input tax input tax for that VAT. So when you look at operation, you have to look at those finer details and then maybe structure your business uh separately where you have mining operation, you have pool uh management, you have uh service management, all of those are separate so that you can claim the as much input tax credit as possible. >> Yeah, a lot of subtleties to this, right? So, let's pivot now and talk about the mining stuff. This is what we're all here to listen to. The mining activities. If you have a lot of minor setup, you might be realizing mining rewards on a really frequent basis, multiple times a day. And so, when you're taking in those rewards, most would come to the conclusion, there is some guidance in the US on this, that whenever you take in those rewards, that is income. And you've established that income by tunch. Imagine that you have a large mining operation and you're hitting multiple times a day taking in new tanches. That is likely to be taxed on receipt at the value at the time you received it the minute you have dominion and control of those assets. But we were watching the price of Bitcoin move around all the time. So think about how granular you want to track that because whenever you're taxed on it, that informs basis. If you pick up $77,000 worth of Bitcoin per per Bitcoin at the time that it's taxed, you're you're paying income tax on that that's taxable. That establishes your basis. The next day, if you're paying if if you're picking up mining rewards and it's like $85 grand, then you've established $85,000 of basis per Bitcoin. This is important to track on a trunch bytrunch basis. If you are doing a lot of this stuff, high volumes activity, can you aggregate this? maybe, but there's a lot of planning involved and you want to make sure you have methodology set up to be systematic and rational to track those tanches, attach attach basis, and then get it into a system so you can track it on ongoing basis. Again, we don't have a ton of rules on point, but in in um in the fall of 24, the IRS dropped some pretty sizable treasury regulations allow us to say this is how you track basis on different tanches of fungeible assets. pretty instructive to what's going on, but it's a highly manual process or you can get a subleddger involved. So Jeffrey, why don't you now take us in the world of how to make all that stuff real so we're not just doing stuff in Excel. >> Thanks Rob. Exactly. If you have let's say if you have 10 pabytes of uh mining power and then uh and then amount of transaction that you'll generate per day is about 300 and then per year that's upwards to 200,000 and then those are each of trenches you have to calculate manually or track manually. But with a subleure like us, we're actually per each of trench, we're a able to get per second uh bit uh block generation time time stamp. What's the pricing fair market value at that given point? How are we calculating that fair value? We have provide proof on that able to reconcile between the onchain data versus uh versus the pool CSV that they provided. if you couldn't find if it's those are mismatching then if you find later on that'll be way too late and then um other things everything is all in the system so whenever you click on any of those transaction you are able to see all of those data provided one of the simple tests I like to provide my client to test whether there's data is sufficient for the test is that find a transaction 12 months ago click on it to see if you have all the data points already for you if not then you might need to find a better solution for your uh current system. If you are you already have those that means you're in a good place and maintain that >> and and you started referencing the data elements critical importance here because it's not just the outputs from your system but we need to feel comfortable that you can drill down and gain a sense of comfort as to the data elements Danny right this is coming from your shop because we get questions right that we've been through IRS exam on this they want to go down prove to prove to me the IRS that that source data can support what's coming out of your subleddger system. So Danny, now you're in the hot seat. >> Yeah. Yeah. I'll I'll be brief with this, but um you know, we went in the weeds there intentionally to show that like there's a lot of moving pieces here, but with anything that can be super opportunistic, it it's important to be organized. And so again, I can speak to this through the blockware lens very simply. You can CSV export all of this information. you know, export all of this information out in CSV format, which provides the data necessary to input into the system so that you can take advantage and be compliant with the the tax rules associated with the opportunity, right? So, um, it's important to be organized and one thing we strive to do is make it incredibly simple so you can not worry about the all, you know, all the intricacies per se. >> So, so the big takeaway here, books and records are critically important. Books and records for things like bit point Bitcoin mining are going to feel a little different than traditional books and records we have in in an ordinary brick-and-mortar businesses. You need to be organized in the way that it's reported out and the ability to go back and prove where it came from. Nobody's going back to a bank wreck anymore. Not in this space. The source data that we're talking about comes back to the infrastructure. How do you prove it out and then associate it back with the data so that you're ready for your external auditors or the IRS? Really a big deal. Okay. Books and records, systematic and rational. Remember that phrase. All right. So, now let's talk about yield generating activities. I know everybody likes to huddle, but on occasion you may have a disposal or you may want to put it to work. So Danny, one of the things we've been talking about in in in your shop is that you're getting a lot of questions about lending activities. Why don't you start talking about lending activities a little bit? >> Yeah. Um, so I'll put this in the context of think about Bitcoin mining as a wealthgenerating system, right? You're creating you're generating Bitcoin as your revenue. You're generating free cash flow as the business. You're creating a Bitcoin treasury. You you may uh be eligible for significant tax savings in conjunction with the purchase of Bitcoin mining servers AS6. Right now, at the end of this, you have a Bitcoin treasury. You have Bitcoin. I can sell it. I can hold it or I can borrow against it. So, there's a number of different lenders here uh that would probably love to talk to you about these opportunities and um but essentially I'm giving my the theory is I'm giving or the thesis is I'm giving my Bitcoin another job. Its job isn't just to go up in dollarized value. Now I'm able to extract US dollar liquidity out of that Bitcoin via like Bitcoin back loans for example, Bitcoin back lines of credit. And as it pertains to the tax side, what I'm doing is I'm avoiding a taxable event because I'm not selling my Bitcoin treasury. Don't sell your Bitcoin. If you need liquidity, you can borrow against the Bitcoin. You can use that for life or paying, you know, energy bills or you can put it back into this machine and purchase as a closed loop loop example more AS6 that create more Bitcoin that go into my Bitcoin treasury that give me more tax advantages that I can then run the playback again. Right? So we've found you know with our customer base uh folks are very very interested and taking advantage of you know lending opportunities to to just juice this flywheel. So now we're going to wave a really big caution flag over Bitcoin lending because we don't have rules on point to protect you if you have a Bitcoin and you lend it to another party. There is no rule on point that says that's not a disposition event. That was a double negative. That means there's risk that when you lend it to another party or use as collateral that you have disposed of that Bitcoin from a tax perspective. Remember that someday we may have rules in the US and abroad similar to securities lending which do have a safe harbor protect in this dynamic. We do not have that today. There's theories and you can go back to tax principles but this is what's important. You need to design with the agreement and also design in the tech what is actually happening that the first test is was there a transfer of ownership. Okay. And if and and if you did have a transfer of ownership, you need to look to other principles out there to protect against dispos disposition event. But do not assume that if you lend your Bitcoin out or use as collateral that you didn't have a disposition event. If you're worried about it, let's go back to books and records. Could you choose a Bitcoin today? If you lend it out today and it's 77 grand, could you choose a Bitcoin that's you you actually mined at 77 grand so you don't have a lot of unrealized gain. You would choose that one. And there's rules in the US for spec ID to choose that Bitcoin and minimize your risk, right? You would choose that one versus the one you mined at 13 grand probably. All right. So Jeffrey, now to give us outside the US, what are you seeing in terms of yield generating activities outside the US? >> Yep. So for other countries like say um for other places let's say Hong Kong or Singapore's um those rules are much simpler. uh we are not uh we are not counting that as disposition but we do see their uh when we talk to our client when we set up this features in our system clients are mostly hesitate about how are we accounting for this transaction this lending is it uh really a disposition or we are just counting this marking towards another party we're marking it as lending and then uh counting it back when we actually uh get it back from the landing so our system actually able to elect both features and then having them to talk to their own advisor who knows about the local law, local tax law and then have them calculate it and then our system able to run both scenario and have them actually able to run both scenario under their management report but nonetheless this is a very interesting topic that we able to incorporate but you have to talk to your advisor locally. Welcome to predict. The world is a market. Everything is a market. Every headline moves the line. Every moment is your market. Call the moves. Bet on your instinct. Your prediction, your edge. Dual bits. Predict where everything is a market. Yeah. And this this the system configuration is really important. People have different points of view. And by the way, your transactions could differ. You you may have one lending activity which triggers gain or loss. You'd recognize on the system. You may have another one that doesn't. But when you do, you want to make sure you're very specific about which ones you're using. Or if you're using your Bitcoin to pay employees or to um pay a vendor out there, you're going to have a disposition event because when you use that Bitcoin, that's a barter transaction. Then you look at which bit Bitcoin did you use? What was your basis? What was the fair value? That's a disposition event. So Jeffrey, now take us into the world of FIFO versus LIFO. What are the methodologies out there that could be used? >> Yep. So around the world, there's different type of uh disposition methodology that that you're able to use for here in the states. We we can use specify for outside of uh uh US. We have uh aggregated uh so we have polling I think in the UK and then we have Germany FO in Canada we can we calculates the average cost. So different places have different weight of calculation in our system when we actually get the disposition we elect the jurisdiction that actually use that law. We can count five or we'll find the first transaction actually match with your disposition or we do the m uh weighted average. We count every inputs to find the the current weight average and it help you calculate it. And here back in the state we're actually able to help you to match which one you want to do to actually uh match the disposition which the with the inputs that you have or we can set it automatically if you want to have the highest hi fo like the highest input and then first out. All of those we can do automatically but all of those you need to find out which uh election you want to do and then set up in the system and then we can run it automatically for you. The rules around the the world differ as to what's allowed. You mentioned average cost that's allowable in some jurisdictions not all. It's actually not an acceptable method here which is surprising to some people but you need to make sure that you have your books and records set up. concept of standing instructions does work. The concept of spec ID does work, but you really need to have those books and records maintained real time and conscious decisions documenting what you're doing. And we go back to the source data. You got to make sure that those books and records can go back and tell you if anybody ever asked you the question, how do we know that that was the source data for that transaction? We come back to you a lot, Danny. Yeah, you're in the hot seat. >> Okay. >> Absolutely. >> Good. Good. Good. All right. So um where where where do you see the future going? So Danny, you live in this space. This is all that you do. What do you see coming next? How do you see mining evolve and and other activities? >> Yeah, I think um I'm going to try to keep this as brief as possible. Uh things are shifting. If you think about the layer stack that goes into uh what you need to stack up to mine Bitcoin, you need land, you need power, you need infrastructure, you need A6. We make this all really simple, but this is all the stuff that goes into it. Land and power and infrastructure are the bottleneck. And right now there is a lot of competition from a little thing called artificial intelligence for every kilowatt hour of energy. That is extremely bullish for Bitcoin mining because the dollarized profit equation for Bitcoin mining is Bitcoin price is your numerator and network hash rate is the denominator. The numerator uh bitcoin price can move at a very high velocity. the denominator hash rate moves at a very slow velocity in a lagging capacity typically because there's a lot of realworld constraints land power energy building data centers billions of dollars of capital so on and so forth so with artificial intelligence coming into play and with a lot of you know publicly traded Bitcoin mining companies kind of pivoting to being infrastructure you know AI hosting companies I think that Bitcoin I think hash price is going to pace up for the foreseeable future through this, you know, having cycle. >> Crystal ball. All right, lightning round. Quick comment. All right, Jeffrey. >> So, I think for the next uh year or so, as soon as uh right now all the tax bureau already have their eyes on the transactions. So now you can't just use Excel to manage your book. You'll need a subleddger to help it. So one thing that we are sharing that we have a lot of agreement with our client is who whoever can s be successful for the next 24 months. It's not just people who can find the low lowest electricity bill uh best text. It is people who can keep their data clean because at the end of day people will start looking at your data. If you can get it clean you're golden. >> Love it. And and here's the other thing that's coming is rules. We are expecting clarity in the rules around tax not just here in the US but around the world. There's a big push on this as the industry matures. It's not just crypton natives getting engaged. We have large mature public companies engaged in mining operations and also other derivatives. We need the clarity to support the space. So that's what I would expect to see. So more to come on that. Thank you all for engaging. This has been great. Enjoy the conference. Every year, this community comes together to celebrate, to debate, to build what comes next. And every year, the stage gets bigger. Sound money, center stage. So, where do you go to celebrate the next chapter in Bitcoin history? You come home. Nashville, July 2027.