Yeah I'm curious about this. But suppose in the future the IRS requires exchanges to report every sale of bitcoin to their customers? Could that be possible? Even though you are hodling & incurring no profit or loss your bitcoin purchases will still be reported & you haven't provided them with your holdings. My guess is your strategy will be reasonably safe if you don't buy anymore btc starting Jan 1st when the new rules take effect. I could be completely wrong of course
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Also there is this: "This plan does not need to be submitted to the IRS, but you will need to keep a copy of it for your records in case you are ever audited."