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Bitcoin Appraiser for IRS

2/23/2020

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Bitcoin appraisal
For Bitcoin donations in excess of $5,000 the IRS requires a signature on Form 8283 which is included with the donors tax filing by a qualified appraiser.
IRS publication 561 defines a qualified appraiser.
Qualified appraiser.
A qualified appraiser is an individual with verifiable education and experience in valuing the type of property for which the appraisal is performed.
  1. The individual:
    • Has earned an appraisal designation from a generally recognized professional appraiser organization, or
    • Has met certain minimum education requirements and two or more years of experience. To meet the minimum education requirement you must have successfully completed professional or college-level coursework obtained from:
      • A professional or college-level educational organization,
      • A professional trade or appraiser organization that regularly offers educational programs in valuing the type of property, or
      • An employer as part of an employee apprenticeship or education program similar to professional or college-level courses.
                3.    The individual regularly prepares appraisals for which he or she is paid.
                 4.    The individual is not an excluded individual.  
Excluded individuals. The following individuals cannot be qualified appraisers for the donated property.
  1. The donor of the property or the taxpayer who claims the deduction.
  2. The donee of the property.
  3. A party to the transaction in which the donor acquired the property being appraised, unless the property is donated within 2 months of the date of acquisition and its appraised value is not more than its acquisition price. This applies to the person who sold, exchanged, or gave the property to the donor, or any person who acted as an agent for the transferor or donor in the transaction.
  4. Any person employed by any of the above persons. For example, if the donor acquired a painting from an art dealer, neither the dealer nor persons employed by the dealer can be qualified appraisers for that painting.
  5. Any person related under section 267(b) of the Internal Revenue Code to any of the above persons or married to a person related under section 267(b) to any of the above persons.
  6. An appraiser who appraises regularly for a person in (1), (2), or (3), and who does not perform a majority of his or her appraisals made during his or her tax year for other persons.
  7. An individual who receives a prohibited appraisal fee for the appraisal of the donated property.
  8. An individual who is prohibited from practicing before the IRS under section 330(c) of title 31 of the United States Code at any time during the 3‐year period ending on the date the appraisal is signed by the individual.
These are the 4 generally recognized professional appraiser organizations - ASA, NACVA, IBA, or AICPA.  
My Bitcoin appraisals are prepared under the AICPA standards as a CPA and other CPAs have peer reviewed my work.  One of my clients has valued art for the IRS for many decades and I have used him as a resource as well.  For the last 5 years I have been performing Bitcoin and crypto donation valuations because of my interest in charity and virtual coin tax compliance. 

If you are considering a Bitcoin donation or virtual currency donation over $5,000 please contact Randy Tarpey CPA to assist with completion of form 8283 including an independent qualified appraisal.  This article is not intended as legal, tax, financial or other advice. So check with your adviser on how the rules may apply to you.  

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    Randy Tarpey CPA 

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