Cyprus vs United States
Crypto regulation comparison
Cyprus
United States
Cyprus regulates crypto under the EU MiCA framework (fully applicable since December 2024). CySEC authorizes crypto-asset service providers (CASPs) while the Central Bank of Cyprus oversees e-money tokens and asset-referenced tokens. Crypto gains from occasional transactions are currently not taxed; active trading is taxed as income at 0-35%. A proposed 8% flat tax on crypto gains is pending parliamentary approval for 2026.
The United States has the world's most complex crypto regulatory landscape, with overlapping federal and state jurisdictions. The SEC regulates crypto securities and has pursued enforcement actions against exchanges and token issuers. The CFTC oversees crypto derivatives and considers Bitcoin a commodity. FinCEN applies BSA requirements to crypto exchanges as money service businesses. The IRS taxes crypto as property: short-term gains at income tax rates (10-37%), long-term gains at 0-20%. New 1099-DA broker reporting rules take effect from 2025. Multiple states have their own requirements, with New York's BitLicense being the most stringent.
Key Points
- CySEC authorizes and supervises crypto-asset service providers under MiCA
- No capital gains tax on crypto for occasional transactions; active trading taxed as income
- EU MiCA regulation applies as an EU member state
- AML/CFT requirements enforced for all crypto businesses
- Proposed 8% flat tax on crypto gains pending parliamentary approval for 2026
Key Points
- SEC regulates crypto as securities under Howey test; major enforcement actions (Ripple, Coinbase, Binance)
- CFTC classifies Bitcoin and Ether as commodities; oversees derivatives markets
- IRS treats crypto as property: short-term gains taxed at 10-37%, long-term (1yr+) at 0-20%
- FinCEN requires exchanges to register as MSBs and comply with BSA/AML requirements
- 1099-DA broker reporting for centralized exchanges effective from tax year 2025
Sources
- IRS - Digital Assets
- CFTC - Digital Assets
- SEC - Crypto Task Force
- Congress - GENIUS Act (S.1582)
- FinCEN - Mining Ruling (FIN-2014-R001)
- IRS - FAQ on Digital Asset Transactions
- IRS - Capital Gains and Losses Topic 409
- FinCEN - Virtual Currency Guidance (FIN-2013-G001)
- IRS - Digital Asset Reporting and Tax Requirements