1-Hour Program

See Credit Details Below


Hedge funds have shown increasing interest in trading cryptocurrency and other digital assets. About one-fifth of traditional hedge funds currently invest in digital assets, with the vast majority reporting that they intend to increase their exposure to digital assets by the end of this year. Furthermore, about one-quarter of traditional hedge fund managers that are not yet invested in digital assets report that they are planning to do so. Investing in cryptocurrency presents special U.S. tax issues for hedge funds, in particular the effect on an onshore fund’s “publicly traded partnership” status and on an offshore fund’s qualification for the “trading safe harbor.”

Join Colin S. Kelly from Fried, Frank, Harris, Shriver & Jacobson LLP as he discusses:

  • Background to and U.S. tax treatment of cryptocurrencies [15 minutes]
  • Basics of hedge fund structuring [5 minutes]
  • Publicly traded partnership rules [10 minutes]
  • Cryptocurrency investing and the PTP rules [10 minutes]
  • Trading safe harbor rules [10 minutes]
  • Cryptocurrency investing and ECI [10 minutes]


Program Level: Update

Intended Audience: In-house counsel, outside attorneys, accountants, hedge fund managers, tax and other allied professionals involved in cryptocurrency trading

Prerequisites: None

Advanced Preparation: None

Credit Details