Author: Iris, CryptoMiao

What do you think virtual currency is? Is it currency, a commodity, or a security?

Currently, discussions and determinations regarding the attributes of virtual currency are taking place in various countries and regions around the world.

For example, the United States passed the "Financial Innovation and Technology for the 21st Century Act (FIT for the 21st Century Act)" in 2024, which specifically categorizes and regulates virtual assets as either "commodities" or "securities." Germany classifies virtual currency as private money. More countries, such as China and Dubai, have classified virtual assets as property in certain cases.

However, as virtual currency gradually becomes popular worldwide, it is time to "unify the measurement standards."

On March 22, 2025, according to Cryptoslate, the International Monetary Fund (IMF) released the seventh edition of the "Balance of Payments Manual" (BPM7), which for the first time qualitatively defines Bitcoin (BTC) and similar virtual currencies and includes them in the balance of payments.

This is the first systematic definition of the status of digital assets by the IMF within the global financial statistical system. Although this classification does not equate to regulatory authorization, its authority is bound to have a profound impact on central banks, finance ministries, tax authorities, and even the crypto industry itself.

Before discussing the implications, attorney Mankun will first talk about how authoritative the IMF organization is.

Who is the IMF?

The IMF, or International Monetary Fund, may sound like a financial organization "far from us," but it actually holds significant weight in global financial rules.

To date, the IMF has been established for nearly 80 years and has over 190 member countries. Similar to the FATF introduced earlier, the IMF is not an affiliate of any one country but a "financial advisor + international data officer + debt firefighting team" built with contributions from various governments, making it an entity that central banks and finance ministries cannot ignore.

The IMF has three main responsibilities:

First, monitoring global economic risks. If a country has high external debt, currency issues, or fiscal distress, the IMF will issue a warning;

Second, providing loans and assistance. If a country is in urgent need of foreign exchange reserves, it can apply for relief loans from the IMF;

Third, and most importantly, which is our focus this time—establishing "global economic statistical standards."

You can think of the IMF as the "chief accountant behind national financial statements." The international balance of payments, capital accounts, and external asset-liability statements we often hear about all rely on the "Balance of Payments Manual" established by the IMF.

For individuals, although the IMF does not directly regulate you like the SEC or tax authorities, the statistical rules it sets will eventually be transmitted step by step to every specific department responsible for "regulating you":

• National statistical bureaus, on how to account for your assets;

• Finance ministries and foreign exchange authorities, on how to monitor your capital flows;

• Tax authorities and regulatory agencies, on whether to regulate you and how to collect taxes.

Thus, the inclusion of BTC and similar virtual currencies in the "statistical category" in this edition of the "Balance of Payments Manual" (BPM7) sends a very clear signal globally: virtual currency is no longer an asset category that can bypass reporting.

While this signal may not immediately trigger regulatory implementation, it will certainly become the starting point for "regulatory action, with basis and measurable energy."

Establishment of Regulatory Standards

Now, let’s return to the section on virtual assets in the latest edition of the "Balance of Payments Manual."

The document states that unbacked crypto assets (such as Bitcoin) should be classified as "non-productive, non-financial capital assets" and listed separately in the "capital account" of the balance of payments.

At this point, if you think that the IMF defining Bitcoin and similar virtual assets as "non-currency" means a relaxation of regulation, you might be mistaken. In fact, this classification may be exactly what global regulatory agencies are most pleased with.

Why do I say this?

As mentioned at the beginning of the article, many countries or regions have long had disagreements over the classification of virtual assets, leading to a "everyone wants to regulate, but no one can regulate" dilemma in cross-border and cross-regional regulation. Now, the IMF has directly concluded: Bitcoin and similar assets are neither money nor debt, but a type of capital asset you hold, similar to gold, real estate, or art.

For regulatory agencies in various countries, this classification is very appropriate. It means that these assets are no longer "gray assets outside the system," but can instead be incorporated into the national asset-liability statistical system, meaning they can be tracked, reported, and even taxed in the future.

It is also worth noting that BPM7 specifically mentions that stablecoins like USDT and USDC, which are backed by liabilities, should be classified as "financial instruments." This provides direct reference for countries in regulating stablecoins, indicating that regulation can refer to the set of rules for financial products. Additionally, platform tokens like Ethereum (ETH) and Solana (SOL) may be viewed as equity-like instruments when held, reflecting their investment attributes.

Thus, from this moment on, there is a handle for regulating virtual assets. With a handle in place, the three areas most directly affected will be: reporting, taxation, and compliance of capital flows.

Reporting Obligations of Holders

For a long time, Web3 has been characterized by anonymity and decentralization. Even though virtual asset data can be found on-chain, regulatory authorities do not know who holds these virtual assets.

However, countries now have reason to include unbacked crypto assets in the statistics of "external capital accounts." This means that as a resident of a certain country, if you control or hold BTC, ETH, or DAO assets that involve non-domestic issuance, non-domestic custody, or whose issuing governance entity is located abroad, they may be included as "external assets in the sense of balance of payments," triggering "foreign asset reporting" requirements.

This is just the first layer; the more critical second layer is that domestic tax authorities are also beginning to strengthen information disclosure requirements regarding "what you hold," regardless of whether the virtual assets are "domestic" or "foreign."

For example, in the United States, if you are a tax resident, even if your assets are on a local trading platform like Coinbase, or you control a non-custodial wallet address, once the value of your held assets reaches a certain amount, you may still need to report it on Form 8938.

Tax Obligations of Traders

Whether Bitcoin (BTC) is treated as a non-financial capital asset or Ethereum (ETH) and Solana (SOL) are treated as equity-like instruments, they must be processed as "asset disposals" and tax obligations fulfilled based on realized profits when disposed of.

Therefore, what virtual asset traders really need to pay attention to is: when will tax obligations arise, and how to calculate taxable income?

For example, if you hold a certain token and then trade it for another token, realizing asset appreciation during the holding period, it may be recognized as capital gains, even if you only conducted a token-to-token trade without converting to stablecoins or fiat currency.

Additionally, staking, airdrops, and providing liquidity yield for certain tokens may be considered ordinary income in some countries, such as the United States, based on the market value at the time received, regardless of whether you conducted a trade or realized profits.

Furthermore, if you are a creator or protocol developer who earns tokens, NFT sales revenue, or protocol fee sharing through on-chain transactions, these may be regarded as business or other taxable income, which must be included in personal or corporate income tax taxable income.

Compliance Challenges of Capital Flows

If the accounting of virtual assets changes the logic of "what you hold" and "taxes on movement," the last unavoidable question is: where do these assets come from, and where are they going?

For a long time, the flow of funds on-chain has been in a phase of technological advancement and regulatory lag. After fundraising, project parties directly transfer stablecoins to developers' wallets, pay salaries, allocate funds, or distribute airdrops through multi-signature addresses. The USDT transfers and BTC payments between users seem to be "walking on-chain by themselves," without banks, reports, or anyone setting up barriers in between.

In the past, these capital flow events were understood as "freedom of transaction" or "user experience," but under the new statistical criteria, they have become "capital project changes" or "financial account income and expenditure," and in some countries, they may trigger applicable thresholds for foreign exchange and payment compliance. Regulatory authorities can then use existing policy tools to cover these.

For Web3 project parties, if the technical team is based domestically but funds are directly transferred from foreign wallets to the team wallet, this structure may be viewed by regulators as "capital inflow" or "capital return," potentially requiring explanations of the nature of the funds, fulfilling reporting obligations, or even facing penalties for fund freezing or foreign exchange violations.

For individual investors, receiving stablecoin transfers using non-custodial wallets, then withdrawing, exchanging, or flowing into fiat accounts, may also be blocked by trading platform risk control systems due to unclear source paths and complex counterparty identities, or they may be required to provide additional KYC and explanations of fund sources.

Summary by Attorney Mankun

It is important to emphasize that BPM7 is not a regulatory rule; it will not directly determine how much tax you owe, whether your money can be transferred out, nor will it immediately lead to KYC, audits, or asset freezes. However, it does quietly transform virtual assets from "unclear" to "classifiable" at the foundational level of regulatory logic.

For regulators, this is a technical breakthrough: moving from "lack of regulatory basis" to "can be incorporated into the system." For the industry, this is a signal: Web3 assets are gradually entering the statistical criteria, policy models, and even the enforcement perspective of the mainstream financial system.

Although the changes brought about by this will not immediately impact every user, for those:

• Project parties still using traditional "offshore income, domestic spending" structures

• Users completing cross-border transactions using stablecoins

• High-net-worth individuals holding large amounts of on-chain assets

it is worth conducting structural sorting and compliance preparation as soon as possible. Especially in the face of increasingly stringent regulations regarding on-chain identity verification, on-chain tax interfaces, and cross-border transaction checks, the cost of proactively adapting is much lower than that of passively responding.

We understand that every Web3 practitioner and user is more accustomed to the narrative of "decentralization" and "free circulation." However, as this BPM7 demonstrates, global regulation is not denying virtual assets but is seeking a way to express them that can be "incorporated into rules."

Since the scoring method of this game has begun to change, at the very least, we need to learn to understand the scoreboard.

免责声明：本文章仅代表作者个人观点，不代表本平台的立场和观点。本文章仅供信息分享，不构成对任何人的任何投资建议。用户与作者之间的任何争议，与本平台无关。如网页中刊载的文章或图片涉及侵权，请提供相关的权利证明和身份证明发送邮件到support@aicoin.com，本平台相关工作人员将会进行核查。