It is May 3, 2026. The IRS has officially closed the “reorganization loophole” for LLCs that hold significant percentages of their treasury in digital assets.
- The Rule: If you change your LLC’s tax classification or move it to a new state, the IRS now considers this a “Deemed Liquidation” of your crypto holdings.
- The Cost: You must pay capital gains tax on the “paper profits” of your tokens at the time of the move, even if you don’t sell a single Satoshi.
- The Shark Insight: “The IRS is treating crypto like a border-crossing asset. If you’re planning to restructure your LLC, do it during a market dip to minimize the ‘Deemed Sale’ valuation. Don’t let a corporate move trigger a million-dollar tax bill you can’t pay.”