Reviewing and optimizing your crypto portfolio for taxes on Accointing is easy with its user-friendly platform and step-by-step guide.

Optimizing your Tax Data with Accointing by Glassnode

Make sure you have set-up all your wallets and tax settings correctly. To begin, navigate to the “Review” tab located on the left-hand side of the platform. This tab houses four sections: “Unknown currencies”, “Identify internals”, “Classify transfers”, and “Missing funds”.

First, head to the “Unknown currencies” tab and check for any coins that can’t be recognized by the platform’s database. If you are familiar with the coin in question, you can add it as a new currency. This will ensure that the platform can accurately calculate the gain or loss on the asset. If the coin is not recognized and you have never heard of it or interacted with it, it may be a scam coin. In this case, you can ask the platform to ignore it.

Next, check for any internal transactions that may have been missed. Internal transactions, which are transfers between two of your own wallets, are not taxable. The platform will flag potential internal transactions, but you should double-check that they are definitely between two of your own wallets. This will ensure that your tax bill is not higher than it needs to be.

To further optimize your portfolio for crypto taxes, you will need to review and classify any transactions that the platform couldn’t do for you. Classifications are labels that tell you why or how a transaction was made and are directly connected to how the assets are taxed. It is important to understand the tax implications of your transactions and to ensure that they are labeled correctly. 

Additionally, you can use the Missing Funds tool to find any missing transactions and make sure that your portfolio is complete. We recommend that you investigate any missing data, however, in the case that you cannot locate the right data, “Fix for me” will add a reconciliation transaction to make sure your portfolio is accurate.

By following these steps, you can stay on top of your crypto tax compliance and ensure that your portfolio is optimized for taxes. 

For additional information on filing your crypto taxes, including 1099 questions, extending your tax return, attachments and filing with multiple tax tools, check out our Crypto Tax Filing Guide 2023.

The information contained in this guide, including any supplemental materials, is for general information purposes and does not constitute financial, investment, legal or tax advice. The present content is not intended as a thorough, in-depth analysis, nor a substitute for a formal opinion, nor is it sufficient to avoid tax-related penalties. Please consult your tax advisor.

Optimizing your Crypto Tax Data with Accointing by Glassnode

In the following quick guide, we explain how deposits and withdrawals are handled at Accointing. The cost basis for taxable disposals is calculated using HMRC's pooling method.

UK Classifications - Accointing by Glassnode

1 – ICO, OTC and Swap classifications act similar to orders. The deposit (acquisition) of the new coins is not taxable, but the withdrawal (coins traded) is taxable. 

2 – Fees that are allocable to a specific crypto asset are included as part of your tax basis within your taxable disposals. These fees represent other fees such as internal fees that are not directly allocable to a specific crypto asset.

3 – Adjustments from use of reconcile function due to variances between imported data and actual balances. Disclosed separately in your tax report.

4 – Treated as nontaxable. The amount is reported separately in your tax report as it may be deductible in limited circumstances; refer to the Tax Guide for deductibility.

5 – Margin gains, losses and fees are reported separately in your tax report. 

6 – Unless it’s a gift to your spouse or civil partner. If that’s the case, classify it as “Remove funds”.

7 – If you maintain beneficial ownership of your assets during the lending period, then this is nontaxable. 

UK Specific Classifications

Are you trying to figure out how to report your cryptocurrency taxes to HMRC? Accointing by Glassnode is a crypto tax and portfolio tracking tool you can rely on to avoid tax reporting mistakes. In this step-by-step guide, we cover everything you need to know to generate your crypto tax report with Accointing and what to do next.

How to File Your Crypto Taxes in the UK with Accointing

Accointing by Glassnode's Crypto Tax Report

Congratulations! You have downloaded your Accointing.com tax reports; what do you do with them? First, let’s take a look at the list of files included with your tax reports and understand what each file is for.

Accointing.com Tax Report (pdf and excel versions)

This is your main tax report containing a summary of all tax-related information for the tax year selected. The Tax Report contains the following sections:

First Page: Contains a summary of your capital gains and losses (including your allowable costs) for capital gains tax purposes and a summary of your taxable income for income tax purposes. Any fees that cannot be directly attributed to a crypto asset, such as internal fees, are also summarized

Taxable Disposals: Lists a summary of your taxable sales or trades by coin. This will include all taxable sales or exchanges subject to capital gain taxes and will break out your gain or loss by coin. Please note that this is only a summary – for the full detail please see the Tax Report Excel File.

Not Taxable Disposals: Provides a summary of your nontaxable disposals

Income: Provides a summary of your taxable income from transactions such as rewards, airdrops, mining, staking or interest, or similar types of income events, and is summarized on page 1 of your tax report.

Margin Gains, Losses and Fees: Provides a summary of any margin trading – gains, losses and fees. Please note that these amounts are not included within your capital gains.

Fees not included elsewhere: Summary of any fees that cannot be directly allocated to a specific crypto asset such as internal transfer fees. 

This is the same report as your Tax Report pdf version, however, it provides the full detail of each and every transaction within each appropriate section (taxable disposals, taxable income, etc).

This file contains all of your gains and losses for the year, taxable or nontaxable – think of this more as an economic gains-and-losses output rather than a tax output. Any taxable transactions will agree to your tax report if the data is filtered out. 

You can also upload this file to Microsoft Excel or Google Sheets to analyze the data.

The Daily Balance csv report contains your balance by wallet for each day of the tax year. For each day of the tax year, you can find your total balance in a given wallet or exchange in GBP (column C) and your balance of each coin in the exchange. 

The Full Data Set csv report contains every transaction in your wallets / exchanges for the taxable year. This report is helpful to trace transactions in other reports or review missing transactions for gaps in your data set.

This report includes all the detail necessary to reconstruct your crypto tax puzzle such as:

Before you can think about filing, you will have to register to file a Self Assessment Tax Return if you intend to file online and you have not registered in the past. If you need to register, you must do so by October 5th of the current year. 

Self-employed: register through your business tax account online.

Not self-employed: register using SA1 online or via mail.

Completing your Self-assessment Tax Return

There are two forms that you will need to complete in order to file your Self-assessment crypto tax return, SA100 and SA108. Follow the directions below to report your crypto taxable income and capital gains.

Report any crypto taxable income on Form SA100, box 17. This includes income such as staking, mining, interest, taxable airdrops and other types of yield. You can find this income in your Accointing.com tax report, page 1 right underneath the Capital Gains section. 

Report any allowable expenses attributable to the income in box 18. 

Enter a description of the income in box 21, such as “Staking” or “Crypto Rewards”. 

In addition to reporting your crypto income, if you had Capital Gains (before considering any losses) in excess of £12,300, or your situation is such that you have to complete a Capital Gains Tax Summary (SA108), check yes to question 7, and complete SA108. You can find more information on whether you should complete a Capital Gains Tax Summary here.

Use your Accointing.com tax report to quickly extract the information you will need to complete your Capital Gains Summary SA108 form. You can follow the notations for the corresponding fields to be used from your Accointing.com tax report:

Number of disposals should be reported in field 14

Total disposal proceeds should be reported in field 15

Total allowable costs should be reported in field 16

Your total gains before considering any losses should be reported in field 17

Capital losses should be reported in field 19

We also provide your net capital gain (loss) in the last field – you do not need to enter this as this just sums up your gains (field 17) and your losses (field 19)

Depending on the tax tool that you use, the input may differ slightly, but the same information is applicable.

If you have any capital losses you are carrying over from the previous year and using in the current year, you will want to report those in box 45. Report trading losses of the current tax year set against chargeable gains in box 46.

Report any losses from the current year to be carried forward into future years in box 47. Box 48 only applies in limited circumstances such as when someone passes away.

Each online tax tool will have different steps when filing your returns with HMRC, although all the required information is the same. All the relevant data and file types you need are included when you download your tax report.

To easily process your self assessment and submit directly to HMRC online, we heavily 

recommend using our UK partner Taxd. Below is a walk through guide on filing your Accointing.com report, on their platform. 

HMRC is very clear in their guidance when they state that:

“Cryptoasset exchanges may only keep records of transactions for a short period, or the exchange may no longer be in existence when an individual completes a tax return.

The onus is therefore on the individual to keep their own records for each cryptoasset transaction.”

We recommend keeping all of the following records indefinitely:

Hot or cold crypto wallet addresses containing taxpayers’ crypto transactions

Other records, such as transaction history files from exchanges (and wallets)

Bank statements or other records showing the deposits and withdrawals of fiat currency

Transaction history containing all of the following information:

Units of crypto and value in GBP at the time of the transaction

Fortunately, all of this information will be automatically kept for you with Accointing.com. You should keep a copy of your tax report, all other files provided (such as the full data set) as well as a copy of any csv or excel files uploaded to Accointing.com. If you’ve used any API and blockchain connections, keep the blockchain address and API keys. In the case you ever get audited, you want to be able to recreate the results.

HMRC automatically impose a £100 late filing penalty for anyone who is required to file a return but misses the deadline; if you already have an online account, the penalty will be charged to it.

Whether or not you owe tax is irrelevant; the penalty is still applied. After three months, additional fines are issued; if there is a substantial amount of unpaid tax, these fines may depend on the amount of tax you owe. You will also be charged interest on any unpaid taxes in addition to these penalties.

The information contained in this guide is for general information purposes and does not constitute financial, investment, legal or tax advice. The present content is not intended as a thorough, in-depth analysis, nor a substitute for a formal opinion, nor is it sufficient to avoid tax-related penalties. Please consult your tax advisor.

How to Report Your Crypto Taxes in the UK (2023)

If you’re trying to figure out how crypto is taxed in the UK, there’s certainly a lot to digest. HMRC have published an extensive manual regarding the tax treatment of cryptocurrencies and digital assets. In this up-to-date UK crypto tax guide, our tax experts explain everything to help you understand your crypto tax liability. You’ll find out when you need to pay tax on crypto, how much is crypto tax in the UK, how to save on your tax bill and how to use a crypto tax tool to file your taxes.

UK Crypto Tax: The Definitive Guide 2023 - Accointing by Glassnode

Buying crypto with fiat currency such as GBP and holding is not taxable. However, when you make any trades or earn income on your crypto, you’ll have to report and pay taxes on your crypto income and gains.

I Made Money in Crypto. Do I Have To Pay Crypto Taxes?

Yes, if you have made money with cryptocurrencies in the UK, you are liable to pay crypto taxes. Any income earned or capital gains from selling or exchanging cryptocurrencies are taxable. The specific tax obligations applicable to your transactions will depend on the type and extent of your activities and your circumstances.

I Lost Money. Should I File Crypto Taxes?

Yes, you should file crypto taxes if you have lost money on your crypto assets. HMRC require you to report any gains and losses from your crypto investments on your tax return. Any losses can reduce your taxable gains, and the excess can be carried forward to future tax years.

I Lost Money in a Bankrupt Exchange. Can I Get Tax Relief? 

HMRC have yet to release any official guidance on claiming tax relief in the UK for funds lost on a bankrupt cryptocurrency exchange. It’s essential to exercise caution if the case of bankruptcy is ongoing, as funds may not permanently be lost and may still be partially recovered or refunded. You should consult a tax expert with your specific situation for precise information on the tax implications of a crypto exchange bankruptcy. 

Yes, crypto mining is taxable in the UK. However, you must first determine if your mining activity qualifies as a trade or business. In either case, mining rewards are taxed based on the pound sterling value at the time of receipt of any coins or tokens received. 

According to HMRC, if the activity does not amount to a trade or business, it’s taxed as miscellaneous income. Any appropriate expenses will reduce the amount chargeable. If the activity amounts to a trade, you must calculate trading profits according to the relevant business tax rules. 

Do I Pay Taxes if I Buy Something With Crypto?

Yes, using cryptocurrency to pay for goods or services is considered a disposal, and it’s a taxable event. 

I’ve Never Filed Crypto Taxes but I Should Have. What Can I Do?

If you owe cryptocurrency taxes from previous tax years, an excellent first step would be to find a tax professional who can help guide you through filing late tax returns. You can also get set up with Accointing to accurately calculate your crypto taxes for any missed years. This will be required in filing any late tax returns.

If you’re wondering how to avoid paying tax on crypto in the UK, remember that tax evasion is a criminal offence that should not be taken lightly. Instead, you can look into ways to legally reduce your tax bill such as tax loss harvesting. 

To file your crypto taxes, you’ll need to generate your tax report. The best way is to use a reliable crypto tax tool. To file your crypto taxes with Accointing, you’ll need to:

Import your data/wallets to the platform 

Make sure you have selected the correct country and tax method

Go through the four-step review process to ensure data is accurate

The following steps will depend on the method you use to submit your taxes. Whether you file directly to HMRC or use an online tool, our How to File Guide covers everything you need to know.

Capital gains tax (CGT) is the tax applied to profit made from selling (or ‘disposing of’) an asset. In simpler terms, if you bought a digital asset and sold it for profit, that profit would be subject to CGT.

When Does Capital Gains Tax Apply on Crypto?

As listed by HMRC, any sales, swaps, or spending of your cryptoassets will be deemed a disposal and liable to capital gains tax. This includes:

When calculating the gain, it is important to note that you do not pay CGT on the entire proceeds of your disposals, only the gain that is made. 

Joe purchases 1 Bitcoin for £20,000 and sells it for £35,000

The capital gain here is £15,000, and Joe is liable to pay tax on this gain based on his capital gains tax rate. 

HMRC states that capital gains up to £12,300 are tax-free for the 2021-2022 tax year. However, this is subject to change for the following tax year. In a statement by the treasury, they announced a reduction in the threshold to £6,000 for the 2022-23 tax year and again to £3,500 the following year. 

What are the UK Crypto Capital Gains Tax Rates?

CGT rates depend on how much income you earn as an individual. If your taxable income is within the basic income tax band of £50,270, you will pay 10% on any capital gain. If you earn more, the rate is 20%. In short:

If your income was less than £50,270 – you will pay 10% on your crypto gains

If your income was more than £50,270 – you will pay 20% on your crypto gains

You can safely use a crypto tax software such as Accointing to get an accurate crypto tax report.  Accointing handles all of the calculations for you. All you need to do is connect your wallets! From here, the platform does all the heavy lifting. You’ll also gain insights into your portfolio that will help you optimise your taxes.

Once you’ve generated your tax report with Accointing, you’ll find these 5 fields across the top of the first page of your tax report.

These have all the information required for you to report your crypto gains. The next steps will depend on your method of filing. Our How to File Guide covers everything you need to know.

For any further information on capital gains tax in crypto, refer to HMRC’s crypto assets capital gains tax guidance.

Income tax applies to any wages, salaries, dividends, interest, or other forms of income earned throughout the year.

Income tax applies to any gain earned from activities such as staking and mining. This is distinguishable from capital gains tax as it doesn’t apply to selling or swapping your assets, but to the rewards you receive from them.

Crypto income can have many forms, but here is a useful rule of thumb. If you open up your wallet (or exchange account) and have more crypto coins than you had before, the new assets are recognised as ordinary income based on their value when you obtained control of the coins.

The standard personal allowance, or individual tax-free income, is £12,570. However, you do not get a personal allowance if you have taxable income over £125,140. It is essential to keep in mind that your income tax allowance also applies to the regular earnings from your employment, whether that be through PAYE or self-employment. 

The table below shows you the tax rates applicable for each band (basic rate, higher rate, additional rate) based on your taxable income. 

More info and guidance can be found from HMRC. 

If you have participated in activities such as staking, mining, airdrops or any event subject to income tax, then it needs to be reported in your tax return.

With Accointing, once you connect your wallets, the platform will calculate everything for you. As shown below, Accointing will break down your taxable income on the first page of your tax report. This is reported on the SA100 form when completing your tax return. For more information and a step-by-step walkthrough, head to our How to File Guide.

As listed in the capital gains section of this guide, taxable disposals are extremely common in crypto. This section delves into the details, looking at the specific rules and scenarios that are essential to be mindful of when calculating your crypto taxes. 

The pooling method refers to the tax methodology used by HMRC and determines the cost basis for your assets. It does this by grouping the same assets in your portfolio together in a section 104 pool; this creates an average cost for each asset.

Joe’s section 104 pool would be £41,000 (£4,000 + £8,000 + £29,000). From here we can find out the cost per coin by dividing the pool by number of assets. 

In this case, the cost per coin would be £13,667 (£41,000/3 BTC). 

If Joe sold 1 BTC for £40,000, his gain will be £26,333 (£40,000 – 13,667). Let’s see how this works in an example similar to HMRC’s.

Less allowable costs £41,000 x (1/3) (£13,667)

Pooled cost remaining, £27,333 allocable to 2 units of BTC

The ‘bed and breakfasting’ rule exists to prevent taxpayers from selling coins with unrealised losses, deducting the losses, and purchasing the same coins back, putting themselves in the same position as before but having claimed the tax losses.

If you dispose of coins/tokens and then repurchase the same coins/tokens within 30 days, then you use the basis of the newly purchased coins against your sale. Any excess coins acquired over what you disposed of go into the section 104 pool.

To simplify, If you have sold coins to harvest losses and want to avoid the bed and breakfasting rule, wait to buy back the same coins after 30 days. Finding another asset correlated to your first asset would be best if you want to keep market exposure during this period.

This rule exists to simplify reporting in cases where multiple coins of the same type are acquired and disposed of by the same person on the same day. 

Rather than having to refactor the section 104 pools at each purchase and sale, all coins acquired that day are treated as if they were acquired in a single transaction, while all coins disposed of that day are also treated as disposed of in a single transaction. 

After this, the acquisitions get matched to the disposals so that only the excess goes into a section 104 pool (or uses section 104 pool costs if there are excess sales). Note that the 30-day rule (bed and breakfasting) would be considered before the section 104 pool.

While it is unlikely taxpayers with an extremely high trade volume may be eligible to report their actions as trading, not investing. However, there is no bright-line test to determine this.

It’s worth noting that HMRC reiterates this concept throughout their Cryptoassets Manual. What we can conclude from this is that for you to qualify as a trader, you should actually have a business trading and not merely a hobby. 

How can you tell if you are in a trade? HMRC points us to BIM56800, which explores case law and other circumstances. If you are still determining whether your trading is considered a financial trade, it is best to seek advice from a tax professional.

If your activity is considered trading, you will be responsible for Income Tax on your financial trade. If your activity doesn’t count as trading, it’s an investment activity and will therefore be subject to Capital Gains Tax. 

Unfortunately, it’s common in crypto that an issuer of a coin (or NFT) disappears and leaves investors with a worthless asset. 

UK Crypto Tax: The Definitive Guide 2023

Have you got questions on how to pay taxes on NFTs in the UK? Like other cryptocurrency transactions, buying and selling digital art, collectibles, and other unique digital assets in the form of NFTs comes with tax implications. Our tax experts have prepared this up-to-date NFT tax guide to help you understand the latest tax rules surrounding NFTs in the UK. You can find information on calculating and reporting CGT on NFT sales and any income earned from holding an NFT.

NFT Taxes UK: The Ultimate Guide 2023 - Accointing

An NFT is a one-of-a-kind token on the blockchain to which you can embed any digital media file, such as a picture, song, or movie. 

NFTs are tokens that run on top of a smart contract layer one blockchain, such as Ethereum, Solana, or Cardano. Think of the layer one blockchain as an operating system, such as iOS or Android. The NFTs are then tokens launched on each particular operating system. 

To purchase these NFTs, users must generally use the blockchain’s native coin. For example, if you want to buy an NFT on the Ethereum network, you need ETH to make the purchase. The majority of NFT transaction fees are paid in the coin of the blockchain used.

NFT markets such as Open Sea or Magic Eden make trading these tokens possible. Although many other use cases exist, most of the projects listed are digital art collections. 

As an NFT holder or investor, you should know that NFTs are currently subject to income and capital gains tax (CGT). CGT applies to any disposal of an NFT you hold. Selling or swapping an NFT for a profit or loss will be subject to CGT.

Income tax applies to any earnings or interest you make from holding an NFT. These earnings could be in the form of cryptocurrency or more NFTs. The NFT income section of this guide breaks down these scenarios in more detail.

Simply put, NFTs are another blockchain-based digital asset class, similar to cryptocurrencies. Therefore, they’re taxed as an investment property, and any gains from selling NFTs will be subject to Capital Gains Tax.

The only subtle but essential difference to be aware of when calculating these gains is that multiple NFTs cannot be pooled together.

HMRC’s guidance states that NFTs are individually identifiable as unique tokens. As a result, you should not use the section 104 pooling method. Instead, each NFT will be taxed as if it had its own section 104 pool and have any gains or losses calculated accordingly. 

When calculating the gain, it’s essential to note that you do not pay CGT on the entire proceeds of your disposals, only the gain that is made. 

Accointing can help you keep track of all your NFTs and cryptos in one central location and provide you with the most accurate crypto tax report. If you are left with any doubts about your tax liability, we recommend you consult a tax professional.

Like cryptocurrency, purchasing an NFT with fiat currency is a non-taxable event. However, if you use crypto to buy an NFT on a marketplace like Open Sea, the disposal of the crypto used to pay for the NFT will result in a taxable event.

Like swapping one cryptocurrency for another, specific platforms allow for direct swapping or trading of NFTs. Since you’re disposing of the original asset you held, this makes a taxable event, and CGT applies. 

No. When an individual or a business creates an NFT, no gain is realised from the creation of the NFT. Therefore, it’s not a taxable event.

If the NFT is created as part of a business activity, the costs incurred in the process of creating, such as the cost of the artwork or the programming, can be considered allowable expenses. These can be offset against any income from the NFT’s sale. 

If an NFT airdrop has no value or is a scam, you can report it for £0 or a nominal amount and send it to a burn address. This will dispose of it for £0 proceeds, and £0 cost basis with no impact on your tax return. 

Some crypto wallets, such as Phantom on the Solana network, have a burn function in exchange for a nominal amount of SOL (your proceeds).

If an airdrop of unwanted coins or tokens has more than a nominal value, then it’s unlikely that a taxpayer would refuse it. You’ll likely choose to trade and keep the funds, in which case the transaction should be taxable.

Is sending an NFT between Wallets Taxable?

Transferring NFTs between any of your own wallets is not taxable. The Accointing platform will automatically identify any internal transactions saving you from being taxed on them. 

Do the ‘Same Day’ and ‘Bed and Breakfasting’ Rules Still Apply to NFTs?

We cannot say definitively whether these rules apply because there’s no mention of NFTs in HMRC’s guidance on these rules. However, since NFTs are considered chargeable assets, it would be conservative to assume that these rules still apply.

Check out our comprehensive UK Crypto Tax Guide for more information on same-day and bed and breakfasting rules.

As a holder, some NFTs can provide you with different types of income. For example, you could get an airdrop of an NFT or token for holding a certain NFT. You may also be able to stake your NFT to receive a specific token in return. Let’s take a look at the taxation of both scenarios:

If you receive an airdrop of an NFT or token as a reward for holding an NFT, you must recognise this as taxable income based on the fair market value of the NFT or token received. 

If you earn tokens from staking an NFT, this is taxed the same as staking cryptocurrency such as bitcoin; you recognise any rewards as income based on the fair market value of the tokens at the time of receipt.

Play-to-earn (P2E) games have exploded in popularity over the past couple of years, with the likes of Axie Infinity and Thetan Arena leading the charge. They offer you the opportunity to earn rewards in the form of crypto or other NFTs from playing the game.

The taxation is the same as if you were earning cryptocurrency. As a result, any acquisition of NFTs earned from playing P2E games will be subject to income tax. 

As an NFT project creator or NFT artist, you will be subject to either CGT or income tax on any profits from selling these assets. 

The type of tax will be determined by whether or not the NFTs are considered part of a business activity. If it is concluded that they are, any sales may be subject to income tax rather than CGT. 

This isn’t the only difficulty, as so many unique NFTs are being developed with varying utility; some may be viewed differently and fall into a “grey area” from a tax standpoint. 

In this circumstance, the asset/transaction in question may be subject to a series of tests known as the Badges of Trade by HMRC. 

As NFTs are a rapidly evolving sector of crypto, new advancements and trends often outpaced guidelines. In light of this, we strongly suggest you consult a tax professional to ensure you remain compliant. 

How to Calculate NFT Taxes with Accointing?

To get your NFTs onto the platform, you’ll need to connect the wallets that hold your NFTs. From here, Accointing will calculate any gain, loss or income accordingly. 

If you hold NFTs on an unsupported blockchain, then you’ll need to add the NFT as a custom currency and manually input the cost basis.

Your NFT taxes should be reported using the SA100 form in your self-assessment tax return, as this is where you can input any capital gains or income that you have received through NFTs. 

If you have calculated your NFT taxes using Accointing, then all the information you need will be on your PDF tax report. Our How to File Guide will cover the next steps and provide you with everything you need to know. 

The information contained in this guide (article), including any supplemental materials, is for general information purposes and does not constitute financial, investment, legal, or tax advice. The present content is not intended as a thorough, in-depth analysis, nor a substitute for a formal opinion, nor is it sufficient to avoid tax-related penalties. Please consult your tax advisor.