Bitconnect for ethereum ico
Four million over the time and its purely dependent on public demand. Limited token supplies generate greater demand and value growth. With this, fewer tokens will probably be an available month after month, and consequently, the token worth will increase. Considered one of the main advantages of investing in SYMM is the ability to have immediate liquidity. SYMM funds use proprietary analysis methods to deliver unparalleled shareholder returns with traditional funds investments. Our new DLT environment will scale back these disruptions all through Asia - through a stage that allows finance specialists to be specifically tied to the credit required by small and medium-size organizations that must be developed and can present a most well-liked fee of return than standard savings.
We are searching data for your request:
Upon completion, a link will appear to access the found materials.
Content:
- Please wait while your request is being verified...
- Kryptowährungen bitcoin ethereum blockchain icos &
- Adam Back: Ethereum resembles Bitconnect and Onecoin
- Crypto Weekly | Cryptocurrency, Bitcoin, Ethereum, Altcoin and ICO news from the week
- BitConnect Coin Outdoes Ethereum's Performance for 6 Months That Followed the ICO
- Top 7 Crypto Exchanges for IEOs
- What's a Cryptocurrency Exit Scam? How Do You Spot One?
- “The Godfather of Ethereum” Proposed Reversable ICOs to Let Investors Take Their Money Back
- 3 Times When an ICO Listing and Rating System Could Have Protected Investors
- BitConnect Icon
Please wait while your request is being verified...
With the proliferation of blockchain technology and cryptocurrencies, the Initial Coin Offering ' ICO ' has quickly become the preferred method for blockchain players to raise capital. Singapore has emerged as one of the preferred jurisdictions out of which to conduct ICO s. This is due to a number of factors which include its position as a global financial centre, a conducive start-up ecosystem, and initiatives such as Project Ubin.
Regulators in the United States of America have recently issued a number of cease and desist orders, with Munchee Inc. Not only do these cases serve as a timely reminder, but they are also clearly demonstrate that greater scrutiny is placed on ICO s in general.
An issue that is receiving comparatively little attention is the potential tax exposure of the proceeds from a digital token issue. Set out below are some Singapore tax considerations associated with using a Singapore based structure to conduct an ICO. The Singapore tax system is semi-territorial in nature. The first question which must be asked is whether the proceeds from undertaking an ICO are income. The nature of tokens and cryptocurrencies from a Singapore tax perspective has not been clearly defined and the Inland Revenue Authority of Singapore ' IRAS ' has yet to release any guidance.
These are not legal tender and they generally do not confer any membership interests in the token-issuing entity. To argue that the purchase of a token as akin to a subscription for membership interests would likely be fatal from a securities law perspective if the contrary is intended. There is an extremely wide range of functions attaching to different utility tokens in particular. It is common that they confer usage rights in relation to a blockchain platform or distributed application.
They are, in many respects, not dissimilar to purchasing tickets to see a movie or a sporting event. In the same way that the promoter of a sporting event would be subject to tax on the proceeds from ticket sales, the same analysis applies to an entity undertaking an ICO.
The fact that the revenue associated with using a blockchain or distributed application is received all at once does not change its character as income. Paragraph a applies to bring to tax the proceeds of a trade or business which are carried on by a taxpayer. The idea of carrying on a trade or business typically requires a level of repetition and periodicity.
This is one of the badges of trade which are the indicia generally used to determine whether an activity amounts to the carrying on of a trade.
The fact that a token issuer may conduct no activities other than those in relation to an ICO which is common where an SPV is used as the issuer therefore does not preclude taxation under Section 10 1 of the ITA. An issuing entity based in Singapore may argue that the proceeds from an ICO are foreign-sourced income.
With this characterisation, the ICO proceeds are not subject to Singapore tax as long as they are not received or deemed to be received in Singapore. The source of income has been famously described as a hard, practical matter of fact and so a careful evaluation of all relevant circumstances is required.
The IRAS tends to consider the question of source substantively and look at the place where the decisions leading to the derivation of income are made. This may be compared to other territorial-based jurisdictions such as Hong Kong which arguably place greater weight on the place where contractual formalities take place. A foreign-source argument is more likely to be successful if the developers behind the blockchain technology are based outside Singapore, the ICO is marketed outside of Singapore via participation in industry events and on the internet generally and the participants in the ICO are predominately from outside of Singapore.
It is difficult in abstract to say how robust this position is and Singapore tax advisers will likely differ as to the strength of the opinions they will give — or not give — in view of the facts. Because the Singapore system is territorial, little actually turns on the place of incorporation or even tax residency of an entity when considering the taxation of income under Section 10 1 of the ITA.
Where a foreign incorporated and tax resident entity is used, but the main functions are performed by a development team in Singapore, the source of the income represented by the token raise needs to be carefully considered in the context of Section 12 1 of the ITA. This provision deems the entirety of the income of a non-resident person from a trade or business carried on partly in Singapore and partly offshore to be entirely Singapore-sourced.
It is only that portion of the income which is directly attributable to the operations of the issuing entity carried on outside Singapore which is not caught by this deeming. The operation of this provision makes the question about whether a token-issuing entity is carrying on a trade or business a critical question.
An issuing entity which directly employs staff is more likely to be considered to be carrying on a trade or business than one which merely acts a passive governance vehicle and enters into development contracts with related or third-party developers.
Some blockchain projects have used a Singapore company limited by guarantee as the token-issuing entity. This entity is purportedly established as a non-profit vehicle with the corporate objective of promoting the particular blockchain technology and providing a formal governance structure.
A company limited by guarantee does not have any shareholders and so it can be seen preferable to a company limited by shares by participants in an ICO. This is because the shareholders of a company limited by shares could more readily access the proceeds of an ICO by requiring the directors to distribute profits or return capital.
The ITA provides an exemption for the income derived by charities which are registered or exempt from the requirement to register under the Charities Act Cap. This exemption is not going to apply to a token-issuing entity established as a company limited by guarantee merely because it is stated as being non-profit.
Section 13U of the ITA could, in theory, be used to apply for an exemption from Singapore income tax where a company limited by guarantee is used. This is a broadly crafted provision which exempts the income of a not-for-profit organisation that has been approved by the Economic Development Board. It is however highly doubtful that approval would be given under this incentive scheme.
The potential upfront taxation of token proceeds is made worse by a potential timing mismatch. While the entire proceeds from the token issue may potentially be taxable upfront, it is often the case that the actual proceeds from the token raise will be used to fund development and marketing costs over a period which can stretch to a number of years.
Most jurisdictions have limitations on a taxpayer's ability to 'carry back' and deduct subsequent expenditure against prior year revenue and Singapore is no exception. Section 37E of the ITA provides that current year unutilised capital allowances and losses can only be carried back for one Year of Assessment 'YA' to be deducted against the assessable income for the immediate preceding YA. There are limited examples in case law on the ability of a taxpayer to defer the point of derivation of income for the provision of goods and services where payment was made upfront.
The general rule is that income is earned when the taxpayer becomes entitled to receive income. The taxpayer must have done all that was required to be done to earn the income.
In this case, fees paid upfront for dance lessons were taken to be derived by the dance school as the lessons were provided to students. Notwithstanding that there was no contractual right to a refund from the dance school, the Court found that there was a sufficient contingency that the fees would have to be paid back should the lessons not be provided in due course. This was on the basis that the club's obligation was merely to admit the payer of the entrance fees to membership.
The club was therefore entitled to the entrance fees when it approved an application for membership. Whether a deferral argument is tenable will likely depend on the terms and conditions of the specific ICO in question and the rights attached to the tokens being issued.
In a typical ICO , the terms and conditions make it clear that the purchase of tokens is non-refundable. The issuing entity also makes no guarantee for the completion and deployment of the blockchain platform or distributed application.
In these circumstances, and in light of the decision in ABD , the issuing entity would likely be considered to be entitled to the proceeds from the ICO at the point of receipt. This model is popular for issuers based in or distributing to the US. It is characterised as a pre-funded forward contract for the acquisition of a native token which is issued once a new blockchain project goes live. The whitepaper prepared as part of the SAFT project refer to: saftproject.
The accounting treatment of a transaction is highly relevant — if the SAFT structure results in a deferral of the time at which accounting income is recognised then it may be effective in causing a deferral.
This deferral is however likely to be effective until such time as the blockchain project is released and native tokens are issued. Besides the initial taxability of the proceeds from the ICO , an issuing entity may also be subject to income tax on subsequent realisation gains.
This may include the sale of Ethereum and other cryptocurrencies contributed as part of an ICO , together with the portion of the pre-mine which is retained in treasury by the issuing entity. Singapore does not impose tax on capital gains. The question is therefore whether any sale proceeds realised in this manner are income in nature. The Courts in Singapore apply the 'badges of trade' to assist in making the distinction between income and capital.
This indicia includes such factors as the taxpayer's intention at the time of acquiring the asset in question and whether the taxpayer entered into a series of transactions or simply a one-off transaction.
Looking at these two factors alone, there is a considerable risk that any gains arising will have the character of income. As the Ethereum contributed as part of an ICO is acquired for the specific purpose of disposal to fund the project of the token-issuing entity, the better view is likely that these assets are held on revenue account.
Where the realisation gains made on the disposal of Ethereum and other contributed cryptocurrencies are taken to be income in nature, the next question is whether this is Singapore or foreign-sourced. This is a difficult question which is a matter of fact and degree. It is difficult to ascribe a source to cryptocurrencies which are by their nature decentralised. The IRAS would therefore likely look at a combination of the disposal formalities such as the exchange on which the tokens or coins are sold and the location of the controlling minds behind the decision to sell.
If the mind and management are located in Singapore, there is a strong risk that such gains would be Singapore-sourced income. The use of a Singapore company as a token-issuing vehicle means that it must have at least one resident director to comply with the requirements of the Companies Act Cap.
It is very difficult to build a foreign-source argument in these circumstances for any realisation gains. Utility tokens are not equity or debt securities or other financial instruments at law. The issuance of these tokens to participants in an ICO therefore cannot be an exempt financial supply for GST purposes. The characterisation of the issuance or sale of cryptocurrencies as a taxable supply of services is specifically confirmed by the IRAS on their website.
Where one cryptocurrency is exchanged for another, this is treated as being a barter trade. This means that both parties are taken to have made a taxable supply if they are GST -registered or are required to be GST -registered. The charge to GST is very much dependent on the nexus of both parties to a cryptocurrency transaction with Singapore.
The supplies made by a foreign-incorporated token-issuing entity will potentially be subject to GST in Singapore if the entity 'belongs' in Singapore as this term is defined. This will likely be the conclusion if the token-issuing entity has either a business or fixed establishment in Singapore. These are two separate concepts. An entity will be deemed to have a business establishment in Singapore if it carries on business through an agent or a branch in Singapore.
Under guidance published by the IRAS , an enterprise is treated as having a business establishment in Singapore if its 'main seat of economic activity' is in Singapore. An entity would likely be considered to have its 'main seat of economic activity' in Singapore if the key officers of the entity are based in Singapore or meet and make decisions or carry on activities in Singapore. A fixed establishment on the other hand, is defined as an establishment that has both the human and technical resources necessary to provide the services in question on a permanent basis.
Where a token-issuing company is incorporated in Singapore, it will likely be taken to belong in Singapore. Where a foreign-issuing SPV is used, a careful analysis is required to determine whether it may have either a business or fixed establishment in Singapore. The risk of GST applying is likely limited to the supply of tokens to persons who themselves belong in Singapore. The supply of tokens to non-residents who do not have any nexus with Singapore may be a supply of international services which is zero-rated under Section 21 3 of the GSTA.
It is very common for a share of the 'pre-mine' of tokens in an ICO to be allocated to the promoters of the ICO and other key personnel as part of their remuneration.
An issuing entity will also need to consider if the transfer of pre-mine tokens to promoters and key personnel who are based in Singapore will be subject to GST. It is also necessary to consider the income tax implications which will likely be determined by the location where an employee or contractor is tax resident.
The IRAS guidance on the GST treatment for employee fringe benefits clarifies that an employer is not required to account for output tax on the provision of free services to its employees.
Kryptowährungen bitcoin ethereum blockchain icos &
We use cookies and other tracking technologies to improve your browsing experience on our site, show personalized content and targeted ads, analyze site traffic, and understand where our audiences come from. To learn more or opt-out, read our Cookie Policy. Cryptocurrencies have had a rough week: the value of bitcoin plunged to a mere 50 percent of its peak, and other currencies, such as Ethereum, Ripple, and Litecoin have seen double-digit losses compared to their heights from last year. Tuesday also witnessed the collapse of BitConnect, an anonymously operated crypto exchange that had been repeatedly accused of running a Ponzi scheme via its proprietary BCC currency. Bitcoin has gone through multiple crashes before: in spring , in November , and in January However, this current bubble comes against a new backdrop: a global tide of regulation against the inchoate cryptocurrency industry.
Adam Back: Ethereum resembles Bitconnect and Onecoin
The rise of crypto has brought along a pretty unpleasant and unwanted passenger. As bitcoin BTC and major altcoins have had their time in the sun, an unsavory customer has tagged along for the ride — the crypto scammer. After the very early years of crypto, Asia became the first real center of gravity for bitcoin and altcoins. Right up until the Mt. Gox scandal in Japan and the Chinese crypto crackdown of September , crypto enjoyed exponential growth across the continent. And in their bid to follow suit with seasoned crypto traders and tech-savvy pioneers, many rushed in where angels fear to tread. Scammers were waiting in the wings and took advantage, hatching fiendishly clever schemes that saw thousands of unsuspecting punters parted with their funds forever. In a new three-part series, Cryptonews. BitConnect launched in February to much fanfare and arrived just in time to catch the biggest waves of the bull market that collapsed so spectacularly in early It claimed to be a crypto lending platform that let users trade bitcoin for a native token named bitconnect coin BCC for set periods, picking up interest that was calculated daily — supposedly by a trading bot.
Crypto Weekly | Cryptocurrency, Bitcoin, Ethereum, Altcoin and ICO news from the week
Anyone with a good head on his shoulders would be well aware by now that BitConnect is, point in fact, a straight up scam. While the project appears to be dead and buried, that may not be entirely the case, now that BCC can be used to buy into yet another ICO opening this year, the BitConnectX. Though there are numerous, perfectly legitimate projects, there are also a number of legitimate reasons why the ICO industry has a somewhat shady reputation, owed much to the multiple scams perpetrated in the history of the industry. For one, it does bear the name of BitConnect , which, suffice to say, does not sit very well with a great many investors. Neither will this new open source currency provide any substantial use to the ecosystem.
BitConnect Coin Outdoes Ethereum's Performance for 6 Months That Followed the ICO
The platform had developed its own proprietary trading bot and volatility software that would automatically spot market opportunities. BitConnect utilized a tiered structure that promised varying returns that were dependent on the deposited amount:. However, this also meant that the money a user deposited could not be retrieved throughout the duration of their investment. BitConnect as well as its native coin BCC ultimately went under at the beginning of after multiple cease and desist letters. How the company came to be, who founded it, and what ultimately led to its demise will be covered in the next chapter.
Top 7 Crypto Exchanges for IEOs
Crypto Weekly Cryptocurrency, Bitcoin, Listen now. Obvious exit scam or riskiest investment ever? Plus more! More Episodes See all ». In the financial world that means 10 years of spoofing the price of gold and silver. Augur V2, Teenage Bitcoin scammer and Ethereum 2 around the corner! This week in the news: - As HEX begin advertising huge gains at the sportsball, the side of buses and on taxis, we ask the most important question.
What's a Cryptocurrency Exit Scam? How Do You Spot One?
Honestly, this was recorded quite some time ago so I can't quite remember what we spoke about BUT, here goes:. In the financial world that means 10 years of spoofing the price of gold and silver. Is this the new BitConnect and are we too late?
“The Godfather of Ethereum” Proposed Reversable ICOs to Let Investors Take Their Money Back
RELATED VIDEO: ICO Review - Ethconnect - Ethereum version of Bitconnect?There's a big lesson here for those looking to make a quick profit by snapping up digital currencies, Bitcoin, Ethereum, Litecoin et al, currently trading at a significant discount. In fact, it was considered one of the year's best performing currencies on CoinMarketCap, a leading global index of digital currency prices. You can guess it its reach from the fact that the website was reportedly translated into several Asian languages, including Hindi. The platform basically asked users to use their Bitcoins to buy BCC, which would then be lent out again to the BCC team with a lock-up of months for a guaranteed daily return. But three days ago, the platform suddenly announced that it will close down operations in five days, blaming "bad press", cease and desist orders from the securities regulatory bodies of Texas and North Carolina, and continuous hacker attacks for the move.
3 Times When an ICO Listing and Rating System Could Have Protected Investors
This story also links to cryptocurrency ponzi scheme BitConnect — the scheme collapsed in January, but the tokens were still circulating … until yesterday, when it was delisted from its last exchange, TradeSatoshi. Stephen Palley summarises: Arthur Breitman, Kathleen Breitman, their company Dynamic Ledger Solutions and the Tezos Foundation remain in the case; Bitcoin Suisse AG and Tim Draper are dismissed, and Draper can only be re-added if the plaintiff comes up with a convincing new motion within twenty days. The Tezos Foundation was sufficiently focused on the US to be considered under its jurisdiction. If the SEC is watching which they likely are , this is not a good thing. Binance disclaims the email. This is what it looks like.
BitConnect Icon
Initial Exchange Offerings IEOs are picking up steam, capturing the interest of investors, project teams, and exchanges. The demand for IEOs has been considerable, and can be attributed to several factors. This article will walk you through the rise of IEOs, their unique nature, advantages and limitations and evaluate the IEO offering by some of the top Exchanges. Since the Coinmaster token sale in , ICOs have been the most popular way to fundraise.
There are no comments yet.