– the draft ruling holds that an employee token scheme can fall within the definition of an employee share scheme, with the tax consequences following accordingly.a draft decree to waive corporate income tax and value-added tax for companies that issue digital tokens to the public for investment purposes. Secondary transfers of such tokens will also be exempt from VAT.
For the first time, the 2024 Greenbook introduces into US law a broad definition of digital assets as "any digital representation of value which is recorded on a cryptographically secured distributed ledger or any similar technology as specified by the Secretary." The Greenbook further proposes the imposition of mark-to-market accounting for digital assets and the extension of reporting obligations under the Foreign Account Tax Compliance Act to include digital assets held outside the US by US persons.Puerto Rico offers an “export tax incentive” to certain providers of digital-asset and blockchain activities, which allows businesses that export a service from Puerto Rico to benefit from a 4% corporate tax rate.
The proposed rules apply to activites carried out from February 5, 2022. The notice also clarified the GST/HST rules on cryptoasset mining activities before this date. Specifically, the notice provided that there is no GST/HST applicable in respect of the taxable supply made by solo miners that engaged in mining activities and received payment before February 5, 2022.
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