From the perspective of "lack of regulatory basis" to "can be incorporated into systems", interpreting the latest qualitativeness of IMF for Bitcoin from the perspective of legal reasons

Authors of this article: Iris, CryptoMiao

What do you think is virtual currency, is it currency, commodity or securities?

At present, some countries and regions have discussed and judged the properties of virtual currencies worldwide.

For example, the "FIT for the 21st Century Act" passed by the United States in 2024 has specifically divided and regulated the "commodities" or "securities" of virtual assets; Germany classifies virtual currencies as private currencies; and more countries, such as China and Dubai, determine virtual assets as property in some cases.

However, as virtual currencies gradually become popular around the world, it is time to "unify the weights and measures".

On March 22, 2025, according to Cryptoslate, the International Monetary Fund (IMF) released the Seventh Edition of the Balance of Payments Manual (BPM7), which for the first time qualitatively characterized Bitcoin (BTC) and similar virtual currencies and included them in the Balance of Payments Statement.

This is the first time that the IMF has systematically defined the status of digital assets in the global financial statistics system. Although this classification does not equal regulatory authorization, its authority is destined to have a profound impact on central banks, finance ministries, tax institutions and even the crypto industry itself.

However, before discussing the impact, lawyer Mankun will first talk to you about how authoritative the IMF organization is.

Who is IMF?

The IMF, full name of the International Monetary Fund, sounds like a financial organization "far from us", but in fact, it has a great weight in global financial rules.

So far, the IMF has been established for almost 80 years and has more than 190 member states. Similar to the FATF I have introduced to you before, the IMF is not an affiliate of any country, but a "financial consultant + international data officer + debt firefighter" jointly built by governments of various countries. It is an existence that cannot be avoided by central banks and finance departments of various countries.

There are three main responsibilities of the IMF:

First, focus on global economic risks. The IMF will issue early warnings if any country has high foreign debt, has problems with the exchange rate, and can’t hold on;

Second, provide loans and assistance. If a country's foreign exchange reserves are in urgent need of emergency, you can apply for a bailout loan from the IMF;

Third, the most critical thing is also what we are concerned about this time -formulating "global economic statistical standards".

You can think of the IMF as the "chief accountant behind the national financial statements." The balance of payments statements, capital accounts, and external balance sheets we usually hear about relying on the "Balance of Payments Manual" formulated by the IMF.

For individuals, although the IMF does not directly manage you like the SEC or the tax bureau, the statistical rules it sets will eventually be transmitted to each department that is specifically responsible for 'regulating you':

• Statistical bureaus in various countries, how to count your assets;

• How to monitor your capital flow from the Ministry of Finance and the Bureau of Foreign Exchange;

• Taxation Bureau and regulatory agencies, do you care about whether you and how to collect taxes?

Therefore, the seventh edition of the "Balance of Payments Manual" (BPM7) of this "Balance of Payments Manual" includes BTC and similar virtual currencies into the "statistical category", which is actually a very clear signal to the world: virtual currencies are no longer an asset class that can bypass financial statements.

Although this signal may not immediately trigger the implementation of supervision, it will definitely become the starting point for "regulation to be hands-on, has basis, and has energy meters".

Establishment of regulatory standards

Now, let's go back to the latest version of the Balance of Payments Manual about virtual assets.

The document states that crypto assets without liabilities (such as Bitcoin) should be classified as "non-productive, non-financial capital assets" and are listed separately in the "capital account" of the balance of payments.

Seeing this, if you think that the IMF defines virtual assets like Bitcoin as "non-currency" that means relaxation of regulation, then you may be misunderstood. In fact, such classification may be the result that global regulators are most happy to see.

Why do you say so?

At the beginning of the article, we mentioned that many countries or regions have long-term differences in the classification of virtual assets, which has led to the dilemma of "everyone wants to manage, no one can manage" in cross-border and cross-regional supervision. Now, the IMF directly concluded that Bitcoin and similar assets are not money or debt, but a kind of capital asset you hold, similar to gold, houses, and works of art.

This classification is perfect for regulators across countries. Because it means that this type of asset is no longer a "gray asset outside the system", but can be included in the country's asset-liability statistics system, that is, it can be tracked, declared, or even taxed in the future.

It is also worth noting that BPM7 also specifically mentioned: stablecoins supported by liabilities such as USDT and USDC should be classified as "financial instruments". This also provides a direct reference for countries in the regulation of stablecoin, that is, the set of rules that can be used for regulation to refer to financial products. Moreover, platform tokens such as Ethereum (ETH) and Solana (SOL) may be regarded as equity-like tools when held, reflecting their investment attributes.

Therefore, from this moment on, there is a way to regulate virtual assets. With the grasp, the three most directly affected areas: declaration, taxation and capital flow compliance.

Holder's declaration obligation

Web3 has long been anonymous and decentralized Web3. Even if data on virtual assets can be found on the chain, the regulatory authorities do not know who holds these virtual assets.

But now, countries are beginning to have reason to include debt-free crypto assets in the statistics of "foreign capital accounts". This means that if the BTC, ETH, and DAO assets you control or hold as a resident of a certain country involve non-national issuance, non-national custody, or if the issuance and governance entity is located abroad, it may be included in the "foreign assets in the sense of balance of payments", triggering the "overhead asset declaration" requirement.

This is just the first level, and the more important thing is the second level: the domestic tax authorities have also begun to strengthen the information disclosure requirements for "what do you hold", and this has nothing to do with whether virtual assets are "in China" or "outdoor".

Take the United States as an example. If you are a tax resident, even if your assets are in a local U.S. trading platform such as Coinbase, or you control a non-custodial wallet address, once the assets you hold have reached a certain amount, you may still need to declare them in Form 8938.

Trader 's tax obligations

Whether Bitcoin (BTC) is a non-financial capital asset or Ethereum (ETH) and Solana (SOL) reference equity tools, it must be processed in accordance with "asset disposal" during disposal and fulfilled tax obligations based on the realized profits.

So, what virtual asset traders really need to pay attention to is: when will tax liability arise and how to calculate taxable income?

For example, after holding a certain token, it is exchanged for another token, and the asset appreciation is realized during the token holding, and it is likely to be considered a capital gain, even if it is just a currency transaction and it is not exchanged for stablecoins or fiat currency.

For example, staking, airdrop and liquidity income of certain tokens, in some countries represented by the United States, such passive income will be included in taxable income based on the market value at the time of receipt, regardless of whether you have made a transaction or have achieved profits.

In addition, if you are a creator or protocol developer, and you have obtained 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 income tax tax revenue.

Compliance challenges for capital flows

If virtual assets accounted for changes the logic of "what to hold" and "will pay taxes if it moves", then the last unavoidable question is: where these assets come from and where they will flow.

For a long time, on-chain capital flows have been in a stage of technological promotion and regulatory lag. After the project party raises funds, the stablecoin will be transferred directly to the developer's wallet, and pays wages, grants or airdrops through multiple signing addresses. USDT transfers and BTC payments between users seem to be "going on the chain by themselves", with no banks, no reports, and no one sets up cards in the middle.

In the past, these capital flow events were understood as "freedom of transactions" or "user experience", but under the new statistical caliber, they became "capital account changes" or "financial account receipts and expenditures", and even in some countries, the application threshold for foreign exchange and payment compliance was triggered. Regulation can be covered by existing policy tools.

For Web3 project parties, if the technical team is located in China and funds are directly transferred from overseas wallets to the team wallet, once this structure is viewed as "fund return" or "capital inflow", it may be necessary to explain the nature of the funds, fulfill the declaration obligations, and even face the penalty of fund freezing or foreign exchange violations.

For individual investors, using a non-custodial wallet to receive stablecoin transfers, withdraw, exchange or flow into fiat currency accounts may also be stuck in the trading platform's risk control system due to the vague source path and the complex identity of the counterparty, or are required to supplement the KYC and fund source description.

Summary of Lawyer Mankun

It should be emphasized that BPM7 is not a regulatory rule. It will not directly determine how much tax you should pay, whether your money can be remitted, nor will it immediately bring KYC, audit or asset freeze. But it does quietly, at the bottom of regulatory logic, turn virtual assets from "unclear" to "classified".

For regulators, this is a technical breakthrough: from "lack of regulatory basis" to "can be incorporated into the system". For the industry, this is a signal: Web3's assets are slowly entering the statistical caliber, policy model, and even the perspective of law enforcement in the mainstream financial system.

Although the changes behind this will not immediately impact every user, for those:

• Project parties that still adopt the traditional "overseas collection and domestic flowers" structure

• Users who use stablecoins to complete cross-border transactions

• High net worth individuals holding large amounts of on-chain assets

For example, it is worthwhile to sort out structurally and compliant preparations as soon as possible. Especially in the future, the on-chain identity identification, on-chain tax interface, cross-border transaction verification and other systems are becoming increasingly strict, the cost of active adaptation is much smaller than that of passive response.

We understand that every Web3 practitioner and user is more accustomed to the narrative of "decentralization" and "free circulation". But as BPM7 shows this time, global regulation is not denying virtual assets, but finding a set of expressions that can be "included into the rules".

Since the scoring method of this game has begun to change, at least we have to learn to understand the scoreboard.