We did so on Friday in response to a proposed rulemaking considering how to classify bitcoin and similar cryptocurrency contributions, and whether they should be subject to the same $100 cap as cash.
Citing Bitcoin’s scarcity and its classification as a commodity by the CFTC and property by the IRS, we recommend that the IRS treat bitcoin donations as “in-kind contributions” under the Commission’s regulations, which would require no amendment to the rules and have no lower contribution limits like cash. On that question of a low cash-like limit, we clarify some common misconsceptions present in the Commission’s notice. Namely that bitcoin transactions as untraceable and that bitcoin intermediaries are not BSA-regulated.
We hope the FEC will find these comments useful and let Bitcoin into the campaign trail.