Establishing a Framework for Bitcoin Miners to Make Tax-Efficient Charitable Donations

ABSTRACT Companies of all sizes, including Bitcoin miners, engage in charitable giving. As Bitcoin mining evolves into a substantial industry and integrates into mainstream society, it faces challenges not only from scams and environmental criticisms but also from everyday concerns such as tax compliance. One key area is the role of deductible donations, which sits at the intersection of the cryptocurrency ecosystem and the established U.S. tax system. This paper introduces an innovative approach called “hashrate contracts,” which builds upon the long-standing framework of tolling contracts. Just as tolling contracts allow producers to manage inputs and outputs efficiently while transferring operational responsibilities, hashrate contracts enable charities to assume the income associated with mining activities. This structure not only optimizes tax deductions for Bitcoin miners but allows them to claim a charitable deduction for federal income tax purposes, bridging a key gap between the cryptocurrency ecosystem and established financial and regulatory practices. JEL Classifications: K23; K29; K34.

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Publication Details

Journal
The ATA Journal of Legal Tax Research
Published
2025-07-24
DOI
https://doi.org/10.2308/jltr-2022-010
Primary Topic
Blockchain Technology Applications and Security
Type
article
Field-Weighted Citation Impact
0.00
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article

Establishing a Framework for Bitcoin Miners to Make Tax-Efficient Charitable Donations

Brian Huels, Paul C. Nylen, John Olson
The ATA Journal of Legal Tax Research
Blockchain Technology Applications and Security
article

Establishing a Framework for Bitcoin Miners to Make Tax-Efficient Charitable Donations

Brian Huels, Paul C. Nylen, John Olson
article en

Abstract

ABSTRACT Companies of all sizes, including Bitcoin miners, engage in charitable giving. As Bitcoin mining evolves into a substantial industry and integrates into mainstream society, it faces challenges not only from scams and environmental criticisms but also from everyday concerns such as tax compliance. One key area is the role of deductible donations, which sits at the intersection of the cryptocurrency ecosystem and the established U.S. tax system. This paper introduces an innovative approach called “hashrate contracts,” which builds upon the long-standing framework of tolling contracts. Just as tolling contracts allow producers to manage inputs and outputs efficiently while transferring operational responsibilities, hashrate contracts enable charities to assume the income associated with mining activities. This structure not only optimizes tax deductions for Bitcoin miners but allows them to claim a charitable deduction for federal income tax purposes, bridging a key gap between the cryptocurrency ecosystem and established financial and regulatory practices. JEL Classifications: K23; K29; K34.

The ATA Journal of Legal Tax ResearchVol. 23(2)
University of Wisconsin–Whitewater (US)
Openalex Percentile: Top 73%
Blockchain Technology Applications and Security
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Establishing a Framework for Bitcoin Miners to Make Tax-Efficient Charitable Donations — Brian Huels, Paul C. Nylen, et al. · The ATA Journal of Legal Tax Research (2025) | TGRS Research Map | TGRS