Quick ahead two years and fears concerning the dealer definition have come true. It’s clear that the Treasury determined to broaden the scope of what it deems a dealer no matter the statutory language set by Congress. Whereas there are lots of within the digital belongings trade that do match the pure and conventional understanding of the time period “dealer,” resembling centralized, custodial exchanges, it’s apparent that others, resembling decentralized finance (DeFi) software program builders and non-custodial pockets software program suppliers, shouldn’t be swept up by this definition.

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