Exchange of Property (I.R.C. 1001)

For modifications of debt instruments, see Treas. Reg. § 1.1001-3. The page dedicated to this topic is here.

For modifications of derivatives contracts, see Treas. Reg. § 1.1001-4

For transitions from IBORs, see Treas. Reg. § 1.1001-6

In the context of cryptocurrency protocol upgrades, see ILM 202316008 and Forst, McElroy and Dimon, “Blockchain Tax Principles and New Guidance,” Tax Notes, May 15, 2023. Issues: (1) does taxpayer realize gain or loss on cryptocurrency units held that undergo a protocol upgrade? (2) does taxpayer have an item of gross income under section 61(a) as a result of the protocol upgrade? Analysis based on Commissioner v. Glenshaw Glass and Cottage Savings Assn. v. Commissioner.