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Bitcoin Q&A

 

General Questions

 

Can my committee purchase bitcoins as an investment?

Yes.  In Advisory Opinion 2014-02, the Commission concluded that a committee can purchase bitcoins with funds from its campaign depository for investment purposes.  The bitcoins do not need to be deposited in a campaign depository within 10 days of receipt.  Bitcoins may be received into and held in a bitcoin wallet until the committee liquidates them.

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How do I report bitcoins purchased as an investment?

When the committee sells any bitcoins purchased from funds transferred from a campaign depository, the committee must report any earnings or losses as an "other receipt" (Line 14 for Form 3 filers; Line 21 for Form 3P filers; Line 17 for Form 3X filers).  Losses should be reported as a negative entry. 

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Can I use bitcoins that the campaign buys as an investment to purchase goods or services?

No, committees cannot use bitcoins to purchase goods or services.  The committee must sell the bitcoins and deposit the proceeds into the campaign depository before using the funds to make disbursements for goods and services.

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Can my committee receive bitcoins as contributions?

Yes, a committee can receive bitcoins as contributions.  The Act defines a “contribution” to include “any gift, subscription, loan, advance, or deposit of money or anything of value made by any person for the purpose of influencing any election for Federal office.”  In Advisory Opinion 2014-02, the Commission concluded that bitcoins are "money or anything of value" within the meaning of the Act.

Bitcoins may be received into and held in a bitcoin wallet until the committee liquidates them.  Holding bitcoins in a bitcoin wallet does not relieve the committee of its obligations to return or refund a bitcoin contribution that is from a prohibited source, exceeds the contributor's contribution limit, or is otherwise not legal.

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How do I determine the value of the bitcoins that I receive as a contribution?

A political committee that receives a contribution in bitcoins should value that contribution based on the market value of bitcoins at the time the contribution is received.

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How do I report receiving contributions in bitcoins?

The initial receipt of bitcoins as contributions should be reported like in-kind contributions.  The committee will disclose the receipt of the contribution and also report the bitcoins as a disbursement.  These offsetting entries allow the committee's reported cash-on-hand to remain unchanged while holding the bitcoins outside of a campaign depository.  It is recommended to include the number of bitcoins that the committee received and that the bitcoins were not liquidated.  Please see Advisory Opinion 2014-02, Attachment 1 for an example of how to report receiving bitcoins as contributions. 

Any usual and nominal fees that the processor charges should not be deducted from the reported value of the contribution.  The committee should report the usual and nominal fees and commissions that it pays to an online processor as an operating expenditure.

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How do I report liquidating bitcoins?

Reporting for liquidating bitcoins depends on whether the committee sells to a known purchaser or to an unknown purchaser.

Selling to a known purchaser

If the committee sells the bitcoins directly to a purchaser, and therefore knows the identity of the purchaser, the purchaser is considered to have made a contribution to the committee.  The committee will report the purchaser's name, address, and employer/occupation information as well as the date of the purchase, the value of the bitcoins purchased, and the number of bitcoins purchased as a receipt on the committee's report.  The committee will also report a memo entry disclosing the original contributor's information, date of contribution,  original value of the bitcoins, and the number of bitcoins originally given to the committee. Please see Advisory Opinion 2014-02, Attachment 2(a) for an example of how to report selling bitcoins to a known purchaser.

Selling to an unknown purchaser

If the committee sells the bitcoins through an established market mechanism where the purchaser is not known, the purchaser is not considered to have made a contribution to the committee.  The committee will report the market or exchange's name, and address information, as well as the date of the purchase and the value of the bitcoins purchased.  The committee should also include a notation stating how many bitcoins were purchased and that the purchaser is unknown.  The committee will also report a memo entry disclosing the original contributor's information, date of contribution,  original value of the bitcoins, and the number of bitcoins originally given to the committee.  Please see Advisory Opinion 2014-02, Attachment 2(b) for an example of how to report selling bitcoins to a unknown purchaser.

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