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Trusts and Estates

Where is all my money? The situs of cryptoassets

Cryptoassets give rise to many questions. Some are of general concern. For example: “Are they a bubble, which will soon burst?”; “Do they destroy the environment?”; “Does digital art have any artistic merit?”; and “Why didn’t I buy some Bitcoin a decade ago?”. Others are of concern to particular demographics. This article will explore a question of relevance to private client practitioners, namely, what is the situs of a cryptoasset? The time is apt for considering the issue as HMRC has recently announced that it is to send nudge letters on an “educational” basis to taxpayers it suspects of holding cryptoassets who “may not be aware” of their tax compliance responsibilities.

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