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Japan vs United States

Crypto regulation comparison

← Back to map | Japan | United States
Japan

Japan

United States

United States

Legal
Legal

Japan is one of the world's most comprehensively regulated crypto markets. The Payment Services Act and Financial Instruments and Exchange Act govern crypto exchanges and tokens. Japan classifies crypto as "crypto-assets" and taxes gains as miscellaneous income at rates up to 55%, though reforms to lower this rate are under active discussion.

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.

Tax Type Income
Tax Type Capital gains
Tax Rate 15-55%
Tax Rate 0-37%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FSA (Financial Services Agency), JVCEA
Regulator SEC, CFTC, FinCEN, OCC, IRS, State regulators
Stablecoin Rules 2022 stablecoin law requires issuers to be licensed banks, trust companies, or fund transfer agents
Stablecoin Rules Stablecoin legislation actively being developed in Congress; existing oversight by SEC, CFTC, state regulators
Key Points
  • Crypto exchanges must register with the FSA under the Payment Services Act
  • Crypto gains taxed as miscellaneous income at up to 55% (national + local tax)
  • Japan's self-regulatory body JVCEA sets industry standards for exchanges
  • 2022 stablecoin legislation (revised Payment Services Act) regulates stablecoin issuance
  • Government considering tax reform to apply a flat 20% separate taxation on crypto gains
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
Sources