Free Money, But Not Tax-Free: A Proposal for the Tax Treatment of Cryptocurrency Hard Forks

Cryptocurrency has attracted extraordinary attention as one of the greatest financial innovations in recent years. Equally noticeable are the increasingly frequent cryptocurrency events, such as hard forks. Put simply, a cryptocurrency hard fork happens when a single cryptocurrency splits in two, which results in original coin owners receiving free forked coins. Such hard forks have resulted in billions of dollars distributed to U.S. taxpayers. Despite ongoing regulatory efforts, to date, the Internal Revenue Service (IRS) has yet to take a clear position on the tax treatment of cryptocurrency hard forks. The lack of useful guidance when filing tax returns has left taxpayers genuinely confused in the past few years. To fill this regulatory gap, this Note proposes a framework for cryptocurrency hard fork taxation. It explains the underlying technology of cryptocurrency hard forks, examines the recommended guidelines from the American Bar Association and the Association of International Certified Professional Accountants on cryptocurrency hard fork taxation, and references the current practices in Japan and the United Kingdom to lay a solid foundation for the proposed framework. Ultimately, this Note proposes a two-pronged tax on cryptocurrency hard forks. The first tax is levied on the profit made from the receipt of forked coins, and the second tax is levied on the profit made from the disposition of forked coins. A concrete proposal is provided for the applicable coin valuation, tax basis, holding period, and tax rate for the two prongs. Aiming to propose a tax treatment that is closest to the nature of cryptocurrency hard forks, this proposal considers various practical concerns, such as the inefficiency of the cryptocurrency market, the indirect possession of forked coins through third-party exchanges, and the fluctuating trading prices of forked coins when determining the valuation, tax basis, and holding period. This proposal not only provides clarity for taxpayers in filing tax returns and fulfilling tax obligations, but it also relieves the potential tax deferral and tax evasion problems that arise after a cryptocurrency hard fork

Fork-decompositions of matroids

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Forked Temperley-Lieb Algebras and Intermediate Subfactors

We consider noncommuting pairs P,Q of intermediate subfactors of an irreducible, finite-index inclusion N in M of II_1 factors such that P and Q are supertransitive with Jones index less than 4 over N. We show that up to isomorphism of the standard invariant, there is a unique such pair corresponding to each even value [P:N]=4cos^2(pi/2n) but none for the odd values [P:N]=4cos^2 (pi/(2n+1)). We also classify the angle values which occur between pairs of intermediate subfactors with small index over their intersection: if [P:N] < 4, then the unique nontrivial angle value is always cos^-1 (1/([P:N]-1)).Comment: 19 pages. Stylistic revisions and reference added to Evans-Gould 1994 in which forked TL algebras appea

A Generic Checkpoint-Restart Mechanism for Virtual Machines

It is common today to deploy complex software inside a virtual machine (VM). Snapshots provide rapid deployment, migration between hosts, dependability (fault tolerance), and security (insulating a guest VM from the host). Yet, for each virtual machine, the code for snapshots is laboriously developed on a per-VM basis. This work demonstrates a generic checkpoint-restart mechanism for virtual machines. The mechanism is based on a plugin on top of an unmodified user-space checkpoint-restart package, DMTCP. Checkpoint-restart is demonstrated for three virtual machines: Lguest, user-space QEMU, and KVM/QEMU. The plugins for Lguest and KVM/QEMU require just 200 lines of code. The Lguest kernel driver API is augmented by 40 lines of code. DMTCP checkpoints user-space QEMU without any new code. KVM/QEMU, user-space QEMU, and DMTCP need no modification. The design benefits from other DMTCP features and plugins. Experiments demonstrate checkpoint and restart in 0.2 seconds using forked checkpointing, mmap-based fast-restart, and incremental Btrfs-based snapshots

Symmetry-constrained electron vortex propagation

Electron vortex beams hold great promise for development in transmission electron microscopy, but have yet to be widely adopted. This is partly due to the complex set of interactions that occur between a beam carrying orbital angular momentum (OAM) and a sample. Herein, the system is simplified to focus on the interaction between geometrical symmetries, OAM and topology. We present multiple simulations, alongside experimental data to study the behaviour of a variety of electron vortex beams after interacting with apertures of different symmetries, and investigate the effect on their OAM and vortex structure, both in the far-field and under free-space propagation.Comment: 11 page

Antennal and Mouthpart Sensilla of the Blister Beetle. \u3ci\u3eMeloe Campanicollis\u3c/i\u3e (Coleoptera: Meloidae)

Sensilia on the sexually dimorphic antennae of the blister beetle, Meloe campanicollis, were primarily sensilla chaetica with scattered socketed and non-socketed sensilla basiconica. Forked chaetifonn sensilla on the female\u27s first segment are displaced by the antennal socket rim when the male grasps and lifts her antennae with segments 5 to 7 of his antennae. Segments 5 to 7 lack dense sensilla chaetica and have only patches of shorter sensilla. The segments also contain a high density of epidennal gland ducts compared to other segments. Maxillary palpi apices were similar in males and females, but the female\u27s labial palpi contained fewer narrow and many more short, broad sensilla basiconica than the male·s

Towards Ecology Inspired Software Engineering

Ecosystems are complex and dynamic systems. Over billions of years, they have developed advanced capabilities to provide stable functions, despite changes in their environment. In this paper, we argue that the laws of organization and development of ecosystems provide a solid and rich source of inspiration to lay the foundations for novel software construction paradigms that provide stability as much as openness.Comment: No. RR-7952 (2012