Web3 assets are gradually entering the statistical standards, policy models, and even the enforcement perspective of the mainstream financial system.
Written by: Iris, CryptMiao
What do you think virtual currency is? Is it currency, a commodity, or a security?
Currently, some countries and regions around the world have begun discussions and determinations regarding the attributes of virtual currencies.
For example, the "FIT for the 21st Century Act," passed in the United States in 2024, specifically categorizes and regulates virtual assets as either "commodities" or "securities." Germany classifies virtual currencies as private currencies. More countries, such as China and Dubai, have classified virtual assets as property in certain cases.
However, as virtual currencies gradually gain popularity globally, it is time to "unify the measurement standards."
On March 22, 2025, according to Cryptoslate, the International Monetary Fund (IMF) released the seventh edition of the "Balance of Payments Manual" (BPM7), which qualitatively defines Bitcoin (BTC) and similar virtual currencies for the first time and includes them in the balance of payments.
This is the first systematic definition of the status of digital assets by the IMF within the global financial statistical system. Although this classification does not equate to regulatory authorization, its authority is bound to have a profound impact on central banks, finance ministries, tax authorities, and even the crypto industry itself.
Before discussing the implications, lawyer Mankun will first talk about how authoritative the IMF is.
Who is the IMF?
The IMF, or International Monetary Fund, may sound like a financial organization that is "far from us," but it actually holds significant weight in global financial rules.
To date, the IMF has been established for nearly 80 years and has over 190 member countries. Similar to the FATF introduced earlier, the IMF is not an affiliate of any one country but rather a "financial advisor + international data officer + debt firefighting team" funded by the governments of various countries, making it an entity that central banks and finance ministries cannot ignore.
The IMF has three main responsibilities:
- First, monitor global economic risks. If a country has high external debt, currency issues, or fiscal instability, the IMF will issue a warning;
- Second, provide loans and assistance. If a country is in urgent need of foreign exchange reserves, it can apply for relief loans from the IMF;
- Third, and most crucially, which is our focus this time—establish "global economic statistical standards."
You can think of the IMF as the "chief accountant behind the national financial statements." The international balance of payments, capital accounts, and external asset-liability statements we often hear about all rely on the "Balance of Payments Manual" established by the IMF.
For individuals, although the IMF does not directly regulate you like the SEC or tax authorities, the statistical rules it sets will eventually be transmitted step by step to every specific department responsible for "regulating you":
- National statistical bureaus, on how to account for your assets;
- Finance ministries and foreign exchange authorities, on how to monitor your capital flows;
- Tax authorities and regulatory agencies, on whether to regulate you and how to collect taxes.
Thus, the inclusion of BTC and similar virtual currencies in the "statistical category" in the seventh edition of the "Balance of Payments Manual" (BPM7) sends a very clear signal to the world: virtual currencies are no longer an asset class that can be bypassed in financial statements.
While this signal may not immediately trigger regulatory implementation, it will certainly become the starting point for "regulatory action, with basis and measurable energy."
Establishing Regulatory Standards
Now, let’s return to the section of the latest "Balance of Payments Manual" concerning virtual assets.
The document states that unbacked crypto assets (such as Bitcoin) should be classified as "non-productive, non-financial capital assets" and listed separately in the "capital account" of the balance of payments.
At this point, if you think the IMF defining Bitcoin and similar virtual assets as "non-currency" means a relaxation of regulation, you might be mistaken. In fact, this classification may be exactly what global regulatory agencies are most pleased to see.
Why do I say this?
As mentioned at the beginning of the article, there have long been disagreements among many countries or regions regarding the classification of virtual assets, leading to a "everyone wants to regulate, but no one can effectively regulate" dilemma in cross-border and cross-regional supervision. Now, the IMF has directly provided a conclusion: Bitcoin and similar assets are neither money nor debt, but a type of capital asset you hold, similar to gold, real estate, or art.
For regulatory agencies in various countries, this classification is quite appropriate. It means that these assets are no longer "gray assets outside the system," but can instead be included in the national asset-liability statistical system, meaning they can be tracked, declared, and even taxed in the future.
It is also worth noting that BPM7 specifically mentions that stablecoins like USDT and USDC, which are backed by liabilities, should be classified as "financial instruments." This provides direct reference for countries in regulating stablecoins, indicating that regulation can refer to the set of rules for financial products. Additionally, platform tokens like Ethereum (ETH) and Solana (SOL) may be viewed as equity-like instruments when held, reflecting their investment attributes.
Thus, from this moment on, there is a handle for regulating virtual assets. With a handle in place, the three areas most directly affected will be: declaration, taxation, and compliance of capital flows.
Declaration Obligations of Holders
For a long time, Web3 has been characterized by anonymity and decentralization. Even though virtual asset data can be found on-chain, regulatory authorities do not know who holds these virtual assets.
However, countries now have reason to include unbacked crypto assets in the statistics of "external capital accounts." This means that as a resident of a certain country, if you control or hold BTC, ETH, or DAO assets that involve non-domestic issuance, non-domestic custody, or whose issuing governance entity is located abroad, they may be included as "external assets" in the balance of payments, triggering "external asset declaration" requirements.
This is just the first layer; the more critical second layer is that domestic tax authorities are also beginning to strengthen information disclosure requirements regarding "what you hold," regardless of whether the virtual assets are "domestic" or "foreign."
For example, in the United States, if you are a tax resident, even if your assets are on a local trading platform like Coinbase or you control a non-custodial wallet address, once the value of your held assets reaches a certain amount, you may still need to declare them on Form 8938.
Tax Obligations of Traders
Whether Bitcoin (BTC) is treated as a non-financial capital asset or Ethereum (ETH) and Solana (SOL) are treated as equity-like instruments, they must be processed as "asset disposals" and tax obligations fulfilled based on realized profits when disposed of.
Therefore, what virtual asset traders really need to pay attention to is: when will tax obligations arise, and how to calculate taxable income?
For example, if you hold a certain token and then trade it for another token, realizing asset appreciation during the holding period, it may be recognized as capital gains, even if you only conducted a token-to-token trade without converting to stablecoins or fiat currency.
Additionally, staking, airdrops, and providing liquidity yield for certain tokens may be considered taxable income (ordinary income) based on the market value at the time received in some countries, such as the United States, regardless of whether you conducted a trade or realized profits.
Furthermore, if you are a creator or protocol developer who earns tokens, NFT sales revenue, or protocol fee sharing through on-chain transactions, these may be considered business or other taxable income and must be included in personal or corporate taxable income.
Compliance Challenges of Capital Flows
If the accounting of virtual assets changes the logic of "what you hold" and "taxes on movement," the last unavoidable question is: where do these assets come from, and where are they going?
For a long time, the flow of funds on-chain has been in a phase of technological advancement and regulatory lag. After fundraising, project parties directly transfer stablecoins to developers' wallets, pay salaries, allocate funds, or distribute airdrops through multi-signature addresses. The USDT transfers and BTC payments between users seem to be "walking on-chain by themselves," without banks, reports, or anyone setting up barriers in between.
In the past, these capital flow events were understood as "freedom of transaction" or "user experience," but under the new statistical standards, they have become "capital project changes" or "financial account income and expenditure," and in some countries, they may trigger applicable thresholds for foreign exchange and payment compliance. Regulatory authorities can then use existing policy tools to cover these.
For Web3 project parties, if the technical team is based domestically but funds are directly transferred from foreign wallets to the team wallet, this structure, once viewed by regulators as "capital inflow" or "capital return," may require explanations of the nature of the funds, fulfillment of declaration obligations, and even face penalties for fund freezing or foreign exchange violations.
For individual investors, receiving stablecoin transfers using non-custodial wallets, then withdrawing, exchanging, or flowing into fiat accounts, may also be blocked by trading platform risk control systems due to unclear source paths and complex counterparty identities, or they may be required to provide additional KYC and explanations of fund sources.
Summary by Lawyer Mankun
It is important to emphasize that BPM7 is not a regulatory rule; it will not directly determine how much tax you owe, whether your money can be transferred out, nor will it immediately lead to KYC, audits, or asset freezes. However, it does quietly transform virtual assets from "unclear" to "classifiable" at the foundational level of regulatory logic.
For regulators, this is a technical breakthrough: moving from "lack of regulatory basis" to "something that can fit into the system." For the industry, this is a signal: Web3 assets are gradually entering the statistical standards, policy models, and even the enforcement perspective of the mainstream financial system.
Although the changes brought about by this will not immediately impact every user, for those:
- Project parties still using the traditional "foreign income, domestic expenditure" structure
- Users completing cross-border transactions using stablecoins
- High-net-worth individuals holding large amounts of on-chain assets
it is advisable to conduct structural sorting and compliance preparation as early as possible. Especially in the face of increasingly stringent trends regarding on-chain identity verification, on-chain tax interfaces, and cross-border transaction checks, the cost of proactively adapting is much lower than that of passively responding.
We understand that every Web3 practitioner and user is more accustomed to the narrative of "decentralization" and "free flow." However, as shown by BPM7, global regulation is not denying virtual assets but is seeking a way to "incorporate them into rules."
Since the scoring method of this game has already begun to change, at the very least, we need to learn how to read the scoreboard.
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