Like-Kind Exchange Principles Applicable to Cryptocurrency

Analysis and qualified advice on potential application of pre-2018 like-kind exchange rules to crypto-to-crypto swaps.  Distinctions between different categories of cryptocurrencies.  Work with outside contractor to develop bespoke software to track high-volume transactions (up to mm’s of transactions) tracing through original cost basis and transferred amounts and values in non-recombinant splitting of transfers with differing historical tax basis.  Consideration of overwhelming reporting requirements for high-volume algorithmic traders and pro and con of need for voluminous paper filing on full range of trades.