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Issue:
4903
/
Categories:
Comment & Analysis
, Business Income Manual
, cryptoassets
, FA 2013
, Income Tax
, International
Where’s Wallet?: part two
Key points
- For a UK resident and domiciled individual the source is likely to be largely irrelevant.
- The source (UK income or foreign income) is important for certain categories of people.
- With regard to crypto mining: is the taxpayer operating as a ‘hobbyist’ or conducting a trading activity?
In my article ‘Where’s Wallet?’ (Taxation 3 November 2022) I discussed the topic of situs for CGT and IHT in the context of cryptoassets. Since then case law has moved on and perhaps my own thinking has been refined.
However I don’t want to spend too much time covering that same ground again. This is a discussion of how to determine the source of crypto income and not the situs of assets for either CGT or IHT purposes. I have set out my view on situs in summary at Figure 1. This will be relevant when determining the...
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