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      "author": "steemitboard",
      "body": "Congratulations @craysurveys! You received a personal award!\n\n<table><tr><td>https://steemitimages.com/70x70/http://steemitboard.com/@craysurveys/birthday2.png</td><td>Happy Steem Birthday! - You are on the Steem blockchain for 2 years!</td></tr></table>\n\n<sub>_You can view [your badges on your Steem Board](https://steemitboard.com/@craysurveys) and compare to others on the [Steem Ranking](https://steemitboard.com/ranking/index.php?name=craysurveys)_</sub>\n\n\n**Do not miss the last post from @steemitboard:**\n<table><tr><td><a href=\"https://steemit.com/steemitboard/@steemitboard/downvote-challenge-add-up-to-3-funny-badges-to-your-board\"><img src=\"https://steemitimages.com/64x128/https://steemitimages.com/0x0/![](https://cdn.steemitimages.com/DQmUuJkZdnSpHVWssxF82ntymqXg4Pvk6K6bYvckUYVRsnj/image.png)\"></a></td><td><a href=\"https://steemit.com/steemitboard/@steemitboard/downvote-challenge-add-up-to-3-funny-badges-to-your-board\">Downvote challenge - Add up to 3 funny badges to your board</a></td></tr></table>\n\n###### [Vote for @Steemitboard as a witness](https://v2.steemconnect.com/sign/account-witness-vote?witness=steemitboard&approve=1) to get one more award and increased upvotes!",
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      "body": "Congratulations @craysurveys! You received a personal award!\n\n<table><tr><td>https://steemitimages.com/70x70/http://steemitboard.com/@craysurveys/birthday1.png</td><td>Happy Birthday! - You are on the Steem blockchain for 1 year!</td></tr></table>\n\n<sub>_You can view [your badges on your Steem Board](https://steemitboard.com/@craysurveys) and compare to others on the [Steem Ranking](http://steemitboard.com/ranking/index.php?name=craysurveys)_</sub>\n\n\n**Do not miss the last post from @steemitboard:**\n<table><tr><td><a href=\"https://steemit.com/drugwars/@steemitboard/drugwars-early-adopter\"><img src=\"https://steemitimages.com/64x128/https://cdn.steemitimages.com/DQmYGN7R653u4hDFyq1hM7iuhr2bdAP1v2ApACDNtecJAZ5/image.png\"></a></td><td><a href=\"https://steemit.com/drugwars/@steemitboard/drugwars-early-adopter\">Are you a DrugWars early adopter? Benvenuto in famiglia!</a></td></tr></table>\n\n###### [Vote for @Steemitboard as a witness](https://v2.steemconnect.com/sign/account-witness-vote?witness=steemitboard&approve=1) to get one more award and increased upvotes!",
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      "author": "craysurveys",
      "body": "The Securities and Exchange Commission and the Commodities Futures Trading Commission are the two main federal agencies you will have to deal with if you are involved in issuing, trading or facilitating trading, exchanging, selling, or originating cryptocurrencies (ICOs) or promoting any of the above. \n\nYou may have heard that places like Malta, the Isle of Man, and other places are \"crypto-friendly\" jurisdictions and that, merely by organizing your business there, you are permanently safe from the rules of the SEC and the CFTC. \n\nUnfortunately, this is not the case. If your securities or commodities (virtually all cryptocurrencies are either or both) are available to any American, you must comply with the rules of the SEC and CFTC. Even if you have tools in place to screen out Americans, you are not immune to these regulations. If an American (or someone living in the United States) is able to access your token *even through deception,* for example by submitting a fake non-American identity document that tricks your verification system, your entire offering is subject to SEC and CFTC regulation. \n\nIt is cheaper to comply with the law than it is to try to avoid it. \n\n*Legal Briefs are short, plain interpretations of law. They are written by a licensed attorney. They are not intended as legal advice and do not form an attorney-client relationship with any person.*",
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      "title": "Legal Brief 2: is my cryptocurrency business exempt from SEC/CFTC registration if I organize offshore?"
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      "body": "The Howey Test is the test by which the SEC determines whether or not any given transaction counts as an \"investment contract\" and is therefore subject to the Securities Act of 1933 and attendant regulations. The factors of the test are: \n\n1. An investment of money  \n2. in a common enterprise \n3. and is led to expect profits \n4. solely from the efforts of the promoter or a third party. \n\nThe company issuing the tokens can be the \"third party.\" \n\nIf someone is buying into your ICO with the expectation that you will use that money to grow the value of the token, or if the token represents partial ownership in the company issuing the coin, it will be subject to the Act. Virtually all ICOs will \"pass\" the Howey test and will therefore be subject to the Act. \n\n\n\n\n*Legal Briefs are short, plain interpretations of law. They are written by a licensed attorney. They are not intended as legal advice and do not form an attorney-client relationship with any person.*",
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      "author": "craysurveys",
      "body": "It seems like everyone and their mother has an opinion about why Bitcoin is bad. You've heard them all, and they're mostly nonsense. Bitcoin will never be worth anything, they said until Bitcoin was trading at $18,000 apiece. Bitcoin is only used by drug dealers, they said before being adopted as payment systems by everyone from pizza shops to lawyers ([myself included](http://www.rayatlaw.com)). Bitcoin is too unsafe and stable, they said before financial crises, massive corporate data breaches, currency crises, sovereign debt defaults, and the general disarray of global trade and banking interposed itself between their mouths and your riches. \n\nSo yes, most alleged critical flaws of Bitcoin have turned out to be nonsense. Probably nothing will ever stop truly decentralized, truly distributed digital currencies. But that being said, I have, during my time as an attorney working with several cryptocurrency businesses from exchanges and investment houses through initial coin offerors and developers, identified what I see as four non-obvious but potentially catastrophic problems for widespread adoption of Bitcoin or any other similar virtual currency. \n\nDon't worry, none of them are that Bitcoin is evil, worthless, or fake. \n\n**1. The slow attrition of \"lost\" coins means that Bitcoin will inevitably be exhausted by dumb or careless people**\n\nFive years ago, the good people over at Wired magazine [declared that Bitcoin was worthless and destroyed the keys to their own wallets](https://steemit.com/bitcoin/@proofmaster/5-years-ago-wired-magazine-called-bitcoin-an-abstraction-destroyed-their-wallet-keys-and-now-can-t-access-usd120k-worth-of) as a proud display of how confident they were that Bitcoin would never amount to anything. Five years later, they *still* haven't figured out how to get access to what is now about $120,000 worth of Bitcoin. \n\nLike many idiots, the staff of Wired magazine has permanently removed a few Bitcoins from circulation. There is no way - it is *actually impossible* - to ever recover these lost coins. The key cannot be recovered, because nobody knows it. No system has stored it anywhere. They are totally gone from circulation. \n\nThey would have done less damage to the financial system if they had put 120,000 $1-bills in a pile and burned them because dollar bills can be replaced very easily. At its [normal rate of 38 million new notes per day](https://www.factmonster.com/math/money/facts-about-us-money), it would take the US Mint about four and a half minutes to replace that. Lost Bitcoins, however, cannot really be replaced. While Bitcoins are being mined all the time and introduced into circulation, they have already been \"created\" in the sense that the computer code by which Bitcoins are implied or inferred is already running. There is a maximum supply of 21 million Bitcoins which will all be in circulation by about 2140. Bitcoins that are permanently excluded from circulation by being trapped by idiots in places to which the access keys have been lost have essentially been destroyed. But unlike burned dollar bills, the circulating supply at this time has no built-in technique for rebalancing the supply to make up for the idiot problem. \n\nThese isolated incidents are a trivial problem so far. But given enough time, even an extremely slow attrition of lost keys or otherwise \"destroyed\" coins is a tremendous problem. It seriously accelerates the deflationary nature of Bitcoin. Given a long enough timeline, *all Bitcoins will eventually be lost* on the simple mathematical fact that any attrition rate greater than 0/year, multiplied by the hopefully infinite total lifespan of digital civilization, means that all Bitcoins will definitely be lost in the future. \n\nSome mechanism *needs* to be created to address this because it is a brute mathematical fact that if attrition is greater than zero and supply is finite, then the supply will inevitably be totally lost to attrition. Even if it takes thousands or millions of years, Bitcoin is *necessarily a temporary phenomenon* as a systemic feature of its own design. \n\n**2. A lurking GDPR compliance nightmare is built into the blockchain**\n\nThe [General Data Protection Regulation](http://rayatlaw.com/2018/04/06/the-general-data-protection-regulation-is-coming-are-you-prepared/) is coming. It's mere weeks away as of this writing. Businesses are scrambling to implement their compliance regimes. I won't make you fritter away the rest of your evening listening to all of what the GDPR exactly entails, but here is the key element for purposes of this article: all third parties who may receive the personal data of any customer based in the UK or the EU must be fully disclosed to that original customer, clearly and completely. \n\nFor most businesses this is not a huge deal. If your website is going to forward customer account information over to Salesforce or Mailchimp or some other common data aggregation tool, your compliance is pretty easy - you inform the customer of this information in plain language, you give them the right to opt out, and you give them the power to make you \"forget\" this information on command. But with Bitcoin, this is much easier said than done. \n\nIt is in the nature of the distributed ledger to propagate a customer (a \"data source\")'s information to thousands of computers and across thousands of networks simultaneously. The whole point of the distributed ledger is that you enable an \"election\" every ten minutes to verify each sender, holder, and transaction occurring between them. This means that on paper, if someone builds in any kind of personal identifying information to the blockchain, that information is there *permanently,* and it is readily accessible by *anyone.* \n\nThe GDPR requires that any such third-party access be explicitly disclosed in exacting detail and in plain English. If you sell products to someone and accept Bitcoin in the transaction, are you going to disclose the identity of every single third-party - that is to say, the name of every person and business on the planet that uses Bitcoin - to your customer? Good luck. You'd better start now. \n\nHaving many clients in the cryptocurrency space and others in need of GDPR compliance work, I have puzzled over this problem many times and frankly I don't have an answer for it yet other than that a legislative carve-out to protect distributed ledgers or related blockchain-based technologies from a hyper-literal reading of the GDPR is absolutely essential. Otherwise, the GDPR is a *de facto* ban on the use of Bitcoin, or really any other virtual currency (all Ethereum-based smart contracts, for example, have the exact same impossible compliance problem), from anywhere in the European Union or the United Kingdom. \n\n**3. The perfect balance between asset and currency means that accurate taxation and regulation is impossible**\n\nIs Bitcoin a currency or an asset? \n\nEasy: Bitcoin is a currency. People use it to buy and sell things, or to contract for services. I've accepted retainers in Bitcoin, and paid for everything from office supplies to digital cats using one virtual currency or another. Nobody does that with assets - assets are for *investing in,* currencies are for *spending.* \n\nEasy: Bitcoin is an asset. People buy it and hold onto it hoping that it will appreciate in value so they can sell it. Most Bitcoin transactions are not the purchase or sale of goods or services, they're purchase and sale by and to speculators. Nobody does that with currencies - speculators don't trade currencies or hold them for long periods of time; currencies naturally lose value over time through inflation. \n\nSo which is it? \n\nThe problem is that there are perfectly-balanced good reasons for stating that Bitcoin is an asset and that Bitcoin is a currency. It broadly shares features of both. Bitcoin paradoxically bears features that are facially apposite to both assets and currencies but inconsistent with each other - Bitcoin is highly liquid, yet its main action is in its secondary market. It is mostly bought as an investment, but its loudest champions proclaim its utility as a means of exchange. It was designed, packaged, sold, and shipped as a currency, but has mostly wound up in the hands of investors. \n\n*Caveat investor,* I say - let the investor beware. Right now, Bitcoin is taxed at the federal level as an asset, and yet most states require that persons in the business of buying and selling them acquire money-changers' licensure. A proper regulatory framework cannot develop to accurately capture something that is *both* an asset and a currency, however. In the broad agenda of tax law and financial regulation, assets and currencies occupy completely separate universes, with their own purposes, social goods, and *raisons d'etre.* \n\nLike the looming GDPR nightmare for cryptocurrencies, this problem's fix can only be found in the wisdom of regulators. Which is a huge problem, because... \n\n**4. Regulators are dumb, and they have been completely captured by wealthy donors whose interests are entirely at odds with the social agenda of decentralized finance.** \n\nEarlier this year, we were treated to the amazing spectacle of the US Senate holding hearings about the future of virtual currencies and what should be the appropriate regulations for them. A large group of mostly elderly people who have no idea how technology works, what blockchain is, or probably even how to use their own computers were tasked with implementing effective, pro-innovation regulations for a technology so sophisticated that only a handful of PhDs around the planet have the slightest idea how it works. Oh, GOOD. \n\nThe systemic problem in regulation-making is that the regulators do not understand their regulators. Nobody watches the watchmen on this one - the regulators answer to no one but their wealthy donors, which is yet another layer of elderly wealthy people who have neither the intellect or the need to understand the on-the-ground details of how Bitcoin works. They are at the mercy of the recommendations usually made by a patrician class of corporate patrons whose pecuniary interest is decidedly against the success of distributed and independent financial networks. \n\nIn short, the rules are in the hands of people who are not smart enough to make rules, and who instead defer to the advice of people whose wealth and livelihoods are directly challenged by the success of cryptocurrencies. This is not a recipe for success. We will not see pro-innovation regulation so long as there continues to be a revolving door of money and influence between mainstream financial institutions and the regulators themselves. Best of luck with that. \n\nThese are all potentially lethal flaws with Bitcoin. These reasons are not the bullshit reasons your friends gave you back when Bitcoin was traded at $2 a head (hopefully you held). These are reasons that are baked into the very nature of Bitcoin. They cry out for solutions. I don't know what those solutions are. Maybe some day we'll be able to trust political institutions to find those solutions. Today isn't that day for me.",
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      "body": "I'm an attorney practicing in Massachusetts and New Hampshire. It's important for people to understand that the procedures and local rules of child protective services vary from state to state. The level of involvement required by courts and other third parties varies dramatically. Massachusetts and New Hampshire are night and day compared to each other, for example. Massachusetts is every bit as procedural and bureaucratic as its reputation suggests, where New Hampshire is very different. Find competent local counsel who you trust; there is no one-size-fits-all national template for dealing with any state protective service or fighting a protective order.",
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      "body": "Thank you for your interest in this blog!! liability analysis is a specific aspect of legal/compliance risk. Subsequent posts will be dedicated to more general aspects of risk management. Maybe will look into it in future though (if my blog gains more popularity).",
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      "body": "Another good post, I dig this series. I'm in risk management of a sort myself, as corporate counsel. I wonder if a subsequent post will identify where in the risk management process you think that in-house or general counsel is necessary for liability analysis and where those jobs can fall on other members of a risk management team.",
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      "body": "Effective May 25th of this year, the European Union's General Data Protection Regulation is entering into force as drafted. Compliance is expected on day one: the \"preparation time\" is now, and has been the time since the regulations were proposed for implementation.\n\nHopefully you're ready. The regulations, which are fully effective in the United Kingdom brexit notwithstanding, comprehensively apply to anyone doing business with any person in the European Union or the United Kingdom. You don't have to be based in the EU, organized in the EU, or even necessarily sell any products into the EU - you only need to be transacting business with such a person. Those in businesses like e-commerce, digital services, or other internet-based businesses will quickly realize that this means that the GDPR applies to pretty much all of us.\n\nIf you haven't started yet, the time is now. And you have a lot to do. Beefing up your website terms and conditions to represent, clearly and plainly, all of the data that you receive or acquire from users, how you use it, and how other people use it is just the beginning. All levels of your organization, from human resources down to sales and marketing, need to be involved. The strategic partners who provide your CRM, your outreach and marketing teams, your sales teams, everyone who engages with a customer and is a possible touch-point for customer information as basic as a name or an address needs to be included.\n\nThe process itself is subject to inspection and audit under the GDPR. The effort that you put into compliance counts. Preparation itself is important, but your preparedness, and the process, training, and internal compliance regime that you establish are themselves part and parcel of the GDPR.\n\nThe main thrust of the GDPR is that each person is the owner and custodian of their own data. Each person, having the intelligence and attention span of an approximately average person, therefore deserves to have the actual and potential uses of their data, explained thoroughly. It's an informed consent law for personal data. The high strictures once reserved for health information and credit card data now extends to every meaningful data point about the human person.\n\nBreach preparedness is now more serious than ever before. Regardless of the size or relative seriousness of a data breach, your entire portfolio of personal data must now be alerted within seventy-two hours - rain or shine, Christmas or Arbor Day - of the breach.\n\nThe fines for noncompliance aren't small. 20 million Euros or 4% of the revenues of your firm - whichever yields the greater fine - is on the table. That is to say, the applicable authorities have a more or less plenary power to crush a small business that is noncompliant.\n\nAdd to this the increasingly dizzying patchwork of local rules and regulations - the GDPR grants broad authority to member states to tighten the regulations up and establish local inspection processes - and you are looking at a true compliance headache.\n\nFortunately, both American and European attorneys have already been hard at work streamlining the process. Ray-at-Law included. Contact me today if you're seeking guidance, on any side of the ocean, in GDPR compliance.",
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      "author": "craysurveys",
      "body": "You do a good job of making technical analysis accessible for people like me who are extremely amateurish. I have long wondered whether or not traditional techniques of technical analysis that work on the stock market also work with virtual currencies. Is Bitcoin technical analysis more like analyzing commodities than like stocks? Does it have a completely new and different set of patterns to analyze? Or is it basically the same? I'd be curious to see your thoughts on that. \n\nI don't have enough technical analysis skill or the right software to figure it out on my own, so thanks for helping people like me understand how to look at the trendlines more intelligently.",
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      "body": "![](https://steemitimages.com/DQmTatEGCnYJCznSyT1CU7Bwm1haD3m1xgRtZSLbAiAvudW/image.png)\n\nVirtual currency clients are used to pushing the envelope. They're on the cutting edge of the next great species of digital innovation. Blockchain technology is already the revolution in finance and society we dreamed about as children. \n\nFor this reason, blockchain innovators sometimes act like they're beyond the rules. So many of my clients come when they're at the eleventh hour in response to a terrifying action from the Securities and Exchange Commission, or a complaint from a state regulator, or a nasty demand letter from an investor or lender demanding to know why they're underwriting an enterprise they didn't know was illegally trading securities. \n\nThe most shocking thing about it from a legal perspective is that the cost of complying with the applicable securities regulation is trivial compared to the consequences of ignoring, defying, or trying to dodge them. \n\nThe problem that many innovators share is that they often just don't know what they don't know. Many ICOs are launched by courageous young entrepreneurs who aren't even aware of the vast spectrum of securities regulation. Or maybe they've gotten bad advice - maybe they've been told that just because they call it a \"utility token\" and sell it as a component of technology rather than as an asset issued by a company means that they're in the clear. \n\nThey're not. I'll walk you through the Howey Test, but the long and short of it is that your new token, even if you call it a \"utility token,\" is almost certainly subject to securities registration requirements. \n\nThe test is named for the first lawsuit that explicitly stated the components of the test, which stated as questions, are: \n\n1. Is the alleged security offered for an investment of money? \n2. Is there an expectation of profits from the alleged security? \n3. Is the money invested into a \"common enterprise?\" \n4. Do the profits come from the efforts of a promoter or third party? \n\nProngs one and two of the test are simple. Do you want to make money off of what you're selling? Then yes, step 1 is met. Further caselaw elaborates that step 1 is extremely broad. Investment of equipment or other assets with a readily-ascertainable free market value (for example, other virtual currencies) still counts. And hopefully the answer to step 2 is yes. \n\nStep 3 requires a little bit of definition. A \"common enterprise\" does NOT mean that you have to be an active participant in the enterprise. It does NOT mean that the enterprise in question must be open to the entire world, nor does it mean that it must be closed to a select few. It means only that multiple people must be acting in concert, usually by also making investments for money. \n\nStep 4 should always be yes. If your company is working to improve the value of the coin it is issuing in any way, then yes, congratulations!(?) You have \"passed\" the Howey Test, and now get to go shopping for a securities lawyer.  (Feel free to see my article [here](https://steemit.com/legal/@craysurveys/how-to-shop-for-an-attorney-for-your-ico-utility-coin-offering-or-other-cryptocurrency-project) for how to do that). \n\nMisconceptions abound in the virtual currency community. Many a client will protest: but *mine* is a \"utility\" token! It isn't just a mislabeled piece of stock, it actually does something! \n\nUnfortunately, the original case that created the Howey Test addressed this potential dodge directly: \"it is immaterial whether the enterprise is speculative or non-speculative or whether there is a sale of property *with or without intrinsic value*\" (emphasis added). Whether or not your token represents access to underlying technology is immaterial. Whether or not your actual product is a software suite or other service or product that has almost nothing to do with your token, and whether or not your token will *ever* have any appreciable valuable, are completely irrelevant to the Howey Test. \n\nLooking at the test as a securities lawyer it is hard to see how any ICO could be made that does not fall within the broad parameters of the Howey Test. This is why it is so surprising to me that ICO issuers so rarely seem to get themselves good securities advice. Your coin almost certainly \"passes\" the Howey Test. Whether you choose to be proactive and undergo the very simple, almost routine SEC and state-level compliance this requires of you, or wait for a suit, a demand letter, fines, and possibly jail time, is your call. Make it wisely!",
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      "author": "steem-network",
      "body": "<html>\n<p>Congratulations <a href=\"/@craysurveys\" target=\"_blank\">@craysurveys</a>, you have decided to take the next big step with your first post! The Steem Network Team wishes you a great time among this awesome community.</p>\n<hr>\n<div class=\"pull-left\"><img src=\"https://steemitimages.com/DQmaAdLUJ3yaSkmcmWECWyPGPWcjfbCoZ8Tu4RM6H4DbjCi/steem-network-thumbs-up.gif\" alt=\"Thumbs up for Steem Network´s strategy\" title=\"I suggest Steem Network´s strategy\" width=\"320\" height=\"222\"></div>\n<h1>The proven road to boost your personal success in this amazing Steem Network</h1>\n<p>Do you already know that awesome content will get great profits by following these <a href=\"https://steemit.com/steem-network/@steem-network/spread-your-posts-through-this-proven-strategy-and-get-great-profits-in-return--for-posts-created-at-2018-03-23\" target=\"_blank\" alt=\"Steem Network\" title=\"Follow Steem Network´s suggestions to boost your success\">simple steps</a> that have been worked out by experts?</p>\n</html>",
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      "author": "craysurveys",
      "body": "Here's a harsh truth about the legal industry - most lawyers are not competent to help you with your specific issue. Someone may describe themselves as a \"corporate attorney,\" but not have experience in your specific type of merger or investment deal. Another may be a very competent \"tax attorney,\" but have no idea how to repatriate money from a Swedish tax-deferred corporate investment fund to the United States. You as the consumer of legal services have no guidance in selecting attorneys other than the general representations they make to you. \n\nNowhere is this thornier than in the cryptocurrency space. Attorneys who are otherwise perfectly competent in SEC compliance matters, complex tax issues, or intellectual property matters, may THINK they're the right fit for your ICO, your Coinbase tax returns, or a patent for your blockchain innovation, but generally speaking they have no idea. They only have the general skill set that gets you to find them on Google, and from there you are at the mercy of their incomprehensible CV and their own promises. \n\nI've worked with cryptocurrency issues long enough to know how to smell an attorney who knows what they're talking about, as opposed to one who is trying to graft their generalized expertise which, while impressive, is simply not appropriate for the weird and rapidly-evolving regulatory world of cryptocurrencies. What follows is a questionnaire that you should use liberally when shopping for a lawyer to help you with an issue arising from the natural complexity of cryptocurrencies. \n\nPreliminary matters:\nDoes the attorney have a fundamental understanding of what blockchain technology is and how it works? \nDoes the attorney have a fundamental understanding of the differences between different cryptocurrencies? \nDoes the attorney have a fundamental understanding of how exchanges, mining, and the other major 'institutions' of cryptocurrencies work? \n Does the attorney have the basic vocabulary necessary to speak intelligently with a client about how cryptocurrency works? \n\nRegulatory matters: \nSecurities & Exchange Matters\nCan the attorney adequately explain the jurisdiction of the Securities & Exchange Commission over some virtual currencies? \nCan the attorney appropriately perform a Howey Test analysis on the client's proposed token? \nCan the attorney explain how the marketing of a cryptocurrency might impact the Howey Test? \nCan the attorney explain the different kinds of investors who might be marketed to during an ICO, and under what circumstances? \nCan the attorney adequately identify which exemptions might apply to any given initial coin offering? \nCan the attorney prepare a private placement memorandum? \nCan the attorney prepare a 506(d) filing? \nCan the attorney prepare an accredited investor questionnaire? \nCan the attorney explain the relevance of an initial coin offering that originates overseas, or that is primarily offered to overseas investors? \nCan the attorney explain the reasoning behind the SEC's decision regarding the DAO token?\n\nCommodity Futures Trading Commission Matters:\nCan the attorney adequately explain the jurisdiction of the Commodity Futures Trading Commission over some virtual currencies? \nCan the attorney provide real-world examples of virtual currencies that would or would not fall under the jurisdiction of the CFTC?\nCan the attorney adequately explain what features of a virtual currency would place it under the ambit of the CFTC? \nCan the attorney adequately explain how an exchange or other regular trader might comply with CFTC regulations in offering, purchasing, or selling virtual currencies? 1\n\nTax matters:\nPersonal tax matters\nCan the attorney properly characterize the normal tax treatment of gains from cryptocurrencies? \nCan the attorney properly explain how basis is calculated for a cryptocurrency either purchased or received as payment for services? \nCan the attorney explain the accounting and timing methods that are used to track gains and losses from cryptocurrencies? \nCan the attorney explain the proper tax treatment of cryptocurrencies that are paid to an individual in exchange for services? \nCan the attorney explain the applicability of §1031 exchanges and other standard tax procedures to cryptocurrencies? \n\nBusiness tax matters\nCan the attorney explain the proper classification of a business purchase of cryptocurrencies (i.e., capital asset, R&D asset, etc.)? \nCan the attorney explain the tax implications of using cryptocurrencies to compensate employees and contractors? \nCan the attorney explain the tax implications of using cryptocurrencies or securities representing them in retirement plans? \nIs the attorney familiar with the ERISA rules regarding property as a retirement asset? \nIs the attorney familiar with the preparation of 83(b) elections in regards to capital property held as retirement income? \n\nInternational tax matters\nCan the attorney adequately explain the consequences to a US citizen who invests in cryptocurrencies, or who receives them as payment for work, in a foreign jurisdiction? \n\nIntellectual property matters\nCan the attorney explain the viability of patents for new cryptocurrencies, new blockchain technologies, and explain the general state of intellectual property registrations for novel uses of blockchain technology? \nCan the attorney prepare an intellectual property registration for the WIPO intellectual property office, instead of just the USPTO office? \n\n\nThe general public has very little reference for how good an attorney is for them until after the work is already done - sometimes poorly. Hopefully this brief questionnaire will give you some helpful guidance on how to find out if your securities attorney is a good crypto-securities attorney, or just another securities attorney who will start furiously Googling Bitcoin the moment you leave her office.",
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      "memo": "WANT TO RE-STEEM your all posts for 15 days with 10000+ followers.plus 10 upvotes from diffrant accounts plus 100% @big-whale upvote.send 3 SBD or 4 steem and give your all posts a double chance with 10k followers for 15 days ",
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      "author": "baah",
      "body": ">Tokens like Steem acquire their power and new value from increasing network externalities. Unfortunately, the steep learning curve to the site and difficulty for new contributors to break into the system makes it impractical for a lot of new users from participating much at all. Steemit should be relentlessly focused on growing new users and nothing else, best achieved by:\n\nTokens like anything of value is acquired by belief, and power is no different. \n\nSteemit is a company that holds the hosting for the front end of the system, and when I say the front end I mean that they host noting else, you can create your own front end, youc an even right now FORK this, like GOLOS and make your own steemit that is focused SOLELY on growing new users through whatever whorish means available: such as contracting with the devil. \n\nSteemit isn't about \"basically get paid\", the idea is economic freedom, read the whitepaper. \n\nI am still waiting on a detractor of steem to fork it and I have challenged numerous people to do just that.\n\nIn other words, you might as well save your criticism and get hard at work because none of that is constructive if you understand the ethos behind steem, you're basically explaining how we can rape, murder and kill on the market when we aren't even remotely interested in inflating and blowing up steem as some kind of slut, what good is it gaining the whole world if you lose your spirit in the process? The spirit of steem and steemit has not been Hype, has not been Partnerships with the Devil, has not been masive onboarding, because all those things come from people that are simply and solely interested in profits, numbers and those are at odds with the values of quality. People will come, nobody is going to jump on the first wave, or the second or the 5th but eventually those that happen upon it will accrue, and this is a mathematical fact that as long as there is no better place than steem, more quality AND much more quantity of quality, steem will remain supreme, and I credit it mostly to the values and ethos and WHY behind steem.",
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      "author": "cicbar",
      "body": "I see that this is your first post. Welcome and good luck on Steemit. I like your comment and agree with most of it :-)",
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      "body": "Tokens like Steem acquire their power and new value from increasing network externalities. Unfortunately, the steep learning curve to the site and difficulty for new contributors to break into the system makes it impractical for a lot of new users from participating much at all. Steemit should be relentlessly focused on growing new users and nothing else, best achieved by: \n\n-partnerships with existing social media sites; \n-outreach to new users that focuses on the ability to basically get paid to do what they already do for free on reddit, Facebook, and their own blogs. \n\nThe potential is there but Steemit seems focused on protecting its existing power-users instead of trying to find one. I just joined and would never have heard of this place if not for my overzealous deep reading of every relevant cryptocurrecy subreddit. There is a lot of user engagement on this site for experienced users but the tutorials and FAQs are weak, new users like me are flailing in the dark, and there is no marketing investment from Steemit whatsoever as far as I can see. \n\nWorking on getting listed on new exchanges is of no value if nobody wants to buy the token. The token achieves its value and power not from its concentration in the hands of a small number of power-users, but by expanding the userbase to the point that you have lots of people who have a genuine use for the token. My two cents.",
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