Reuters article celebrates the death of Bitcoin startup CEO Radtke, anyone else completely disgusted by these tackless fools?
I won't link to the article. Headline states that she was a "Bitcoin fanboy and had other problems too." I just can't believe the level of biased hate displayed by a major news source. I can only imagine this young women's family coming across this. The authors have no idea how this women died, but instead of doing any actual investigative work, they seize the opportunity to slam her life's work and interject their own agenda. The battle lines are being drawn. I hope this message of pure hate to the Bitcoin community is met with redoubled efforts to ensure that Bitcoin prevails. Let's all take a moment to realize that none of us get anywhere without walking over bridges created by people such as Radtke. Let's do her justice and continue to think freely and realize the potential that binds us. The authors, JEREMY WAGSTAFF AND RUJUN SHEN must consider themselves to be brave individuals for kicking a dead woman and her grieving family. I think they are void of human compassion.
Bitcoin, Startups, and Suicide: Being an entrepreneur is hard
For over a week now, I’ve been trying to write a year in review piece for Satoshi Forest. The words, which usually just flow like a spigot when I’m passionate about something, seem to just dribble out. And what little eeks by is hardly print worthy. Maybe it’s just writer’s block? Writer’s block happens. Or maybe I’m not as passionate about Satoshi Forest as I used to be? But, I am passionate about Satoshi Forest, perhaps more than I ever have been. And writer’s block, if it is the culprit, cannot explain why I haven’t responded to Elizabeth Ploshay’s ALS Ice Bucket Challenge, in a timely fashion. I guess I’ll have to donate now. You see it’s not just the Satoshi Forest year in review, it’s everything. Emails from friends I haven’t responded to, phone calls I let go to voicemail, new endeavors at Sean’s Outpost I let sit unannounced (http://blockchain.satoshiforest.com/). And then it hits me. I’ve been here before. I’m really depressed. And it seems to be going around. Since the tragic suicide of Robin Williams, four (4) people close to me have also tried to kill themselves. One succeeded. An anecdotal survey of my friends has seen an equal uptick in the number of people talking about or attempting suicide. It’s been really disturbing. In the preparations for the Bitcoin in the Beltway conference this past June, I had one of the more surreal conversations of my life. An east coast sales director for Marriott called me wanting to know if bitcoin was linked to suicide. They had heard of the tragic death of Autumn Radtke in March (http://nypost.com/2014/03/06/bitcoin-firm-ceo-jumped-to-her-death-neighbo) and were concerned about hosting a conference for a technology that was making people kill themselves. I was sure he was joking. He was not. The conversation I had with him must have allayed his fears. #BitcoinBeltway went great, can’t wait to do it again next year. Obviously, bitcoin does not cause suicide. And while we are quick to sticky a “suicide prevention hotline” when the price crashes, bitcoin is not causing depression. What we may want to look into is something that is not bitcoin related, but more something that comes part and parcel with “bitcoiners”. The woes of entrepreneurship and startup culture. Being an entrepreneur is fucking hard. Really hard. Most people don’t even attempt it. It might not feel that way to you, but likely that’s because you surround yourself with other entrepreneurs. Your friends work at startups. Your trips are to startup conferences and conventions. Your news feed is bitcoin and hacker news. You are firmly in the echo chamber. Most people will never try and build a product or company. So most people will never experience what it is like to fear you won’t make payroll and someone else will not be able to pay their rent because of you. Most people will never know how difficult it is to raise money. To get someone else to believe in you enough to open their checkbook and support you financially. The hours you spend and the mental strain that comes from hearing “No” again and again and again. And if you get a “Yes” the pressure doesn’t dissipate! It increases! Now it’s your crazy idea and someone elses money you’re responsible for. Being an entrepreneur is really hard. And we are really hard on ourselves. We are afraid to show any weakness. Because we’ve been taught being weak or vulnerable is to be shunned. If someone asks you how your company is doing “We’re killing. it.” probably comes off your lips before you’ve even processed the question. It is statistically impossible for everyone to always be “killing it”. But ask at your next mixer or meetup and almost everyone will be “killing it”. And that pressure to succeed, to perform, to win is immense. And I think that pressure may be even worse in bitcoin. Not to everyone, but to a lot of bitcoin early adopters, and especially to a lot of early bitcoin entrepreneurs, bitcoin is a promise. A glimpse of a better world free from the inequalities brought by our legacy financial system. So if you fail in bitcoin, it is easy to feel that you are failing on that promise too. I’ve felt that way. Felt that if I screw up I am screwing it up for every non-profit and charity. That they will somehow not get the benefits of bitcoin because I failed. I see it in others. Just a week ago at #Cryptolina I talked with a group of brilliant entrepreneurs who were convinced that if they didn’t beat an incumbent payment solution to market, they had lost the war. And that whole segment of the market would NEVER benefit from cryptocurrency. Being a bitcoin entrepreneur is hard. And I don’t have the answers to how to deal with all the pressure and depression that come from doing what we do. But I have learned a couple of things and maybe someone else that is experiencing depression or having dark thoughts can read this and gain some value from what I’ve learned. And even better, maybe someone that has dealt with depression in the past can riff on what I’ve said and provide some insight into how they cope. 1) You are not alone. When you are depressed, it seems like everyone else has it all together and you are the anomaly. That’s not true. They probably don’t have their shit together either. And everyone has problems we don’t see. Everyone. Some of the greatest entrepreneurs and investors of all time have had brutal fights with depression and suicidal thoughts. READ: http://www.inc.com/magazine/201309/jessica-brudepsychological-price-of-entrepreneurship.html 2) Bitcoin needs you and it doesn’t need you. And that’s ok. Bitcoin needs you. It really does. But it doesn’t need only you, it needs all of us. You are not the single point of failure. Bitcoins success is just a decentralized as the blockchain. So give yourself a break. It’s ok to make mistakes and it’s ok to fail. It’s even ok to fail spectacularly. Think back to how many times bitcoin has been declared dead. How many times has the price crashed? How many times has a major bitcoin institution been corrupted/hacked/found to be a scam? And yet, here we are. An you are here too. 3) It is ok to ask for help. This is hard to learn. We come from a self sufficient culture. And if you ask for help, people will realize that you are not as awesome as they thought you were...BULLSHIT. Asking for help has ZERO bearing on how awesome a person you are. In fact, your friends WANT TO HELP YOU. Being there for you in a moment of crisis is something your friends are probably really down for. But if you ignore them or won’t tell them you are having problems it is really difficult for them to help. Talk to someone. If all else fails you can always call… THE NATIONAL SUICIDE PREVENTION LIFELINE: 1-800-273-TALK (8255) I know all of this might not make a difference. When you are caught up in your head in the middle of a depressive episode nothing seems to help. Try to find something that you can concentrate on just to get you thru the worst of it. For me, I go play with my kids. It helps me. Sometimes more than others. If you are feeling down, try to talk to someone. And if you see someone feeling down, try to lend a supportive ear. Bitcoin needs you alive.
Choice of Entity: Legal Concerns Associated With Founding a Mining Business
Hey everyone, I just wrote something up about the nuances associated with forming a mining business in the United States. It's meant to help people comply with tax reporting requirements in the most business-owner friendly way possible. As always, please consult with your accountant and/or lawyer before acting on any of this information, it's meant to be used as a resource, not as legal advice. I'll be writing up more legal-related news like this in the future, if you'd like more info, let me know and I'll give you the URL of the website I'm working on (still in development but will eventually have lots and lots of useful info like this). *Please keep in mind I am NOT a lawyer (I am in law school, but I have zero credentials as of yet). This should NOT be relied on as your exclusive source of legal information. Without further ado: -------------|Choice of Entity: Legal Concerns Associated With Founding A Mining Business|----------- You're probably wondering, what is the most efficient way to structure a new mining business. While the facts do vary, in the most instances, the answer is as an S-Corporation. Odds are, you're either thinking about setting the business up as an LLC or an S-Corp. Although many think the tax consequences are the same because these are both pass through entities, this assumption is false. S-Corporations are usually going to the be the most efficient tax vehicle for a new mining business. The reason for this is self-employment tax. LLC co-venturers must pay self-employment tax, in addition to their normal individual rate tax, of approximately 17% if they provide a 'service.' Mining is a service! -------------------------------------------|Why is Mining A 'Service'?|------------------------------------------ At first glance, mining may seem like a passive activity. All you do is plug in the miner and it runs in the background all by itself with little to no maintenance required. Where's the service? The easiest way to conceptualize mining as a service is to think about the actual passive version of investing in whatever cryptocurrency one plans to mine. Truly passive cryptocurrency investing simply entails buying a cryptocurrency on an exchange and holding it with the hope of turning a profit. Unlike mining, passive cryptocurrency investing requires no specialized hardware, limited internet connectivity, and minimal power inputs (just the amount required to use your computer to access the internet to buy/sell the cryptocurrency). Unlike investing in cryptocurrency, mining is a business like activity (although in certain instances, it may only constitute hobby income; see section 183 of the Internal Revenue Code and the associated Treasury regulations for more information) that utilizes high tech machinery to solve a variety of complex equations and hash functions. In exchange for solving these equations, miners are rewarded with blocks of cryptocurrency that function as rewards. The cryptocurrency network benefits from miners (unless using a pure Proof of Stake framework, but that is outside the scope of this article) because miners process network transactions in a way that helps secure network stability and security. To hammer the point home, Bitcoin would collapse without miners. Think about the magnitude of that statement. Mining is an essential service for a multi-billion dollar asset class that benefits the national investing public AND the international investing public. Thus, mining is a service. -------------------------------------|Why Does It Matter if Mining Is A Service?|------------------------------- Knowing that mining is considered a 'service' is important when deciding what sort of limited liability entity to use when forming your client's mining business because it drastically affects their future tax liability. ------------------------------|Self-Employment Tax Implications of Operating a LLC|------------------------- LLCs are generally seen as desirable entities for new businesses because of lax corporate governance requirements, extreme freedom of contract, and favorable pass-through tax treatment (unless the founder elects to 'check-the-box' to be taxed as a corporation on the appropriate documents). Additionally, single member LLCs are seen as disregards and have a special tax treatment that will be discussed further elsewhere. For the purposes of self-employment tax, however, single member LLCs (a/k/a disregards) are afflicted by the same malady as member managed LLCs and Manager Managed LLCs--self-employment tax! Self-employment tax has an effective rate of roughly 17% (check these numbers). This tax is ADDED to the LLC member's pass-through tax liability on their tax returns. The governing statute (for self-employment related taxes) is 26 U.S.C. § 1402(a) and the regulations can be found at 26 C.F.R. 1.1402(a)-1, 1.1492(a)-2, and 1.1492(a)-3. This means that if a LLC co-venturer is in the highest tax bracket, they will be paying 37% in individual income tax on all earned income (whether or not distributed to members) PLUS 17% self-employment tax for an EFFECTIVE TAX RATE OF 54%!!!!!!! Even if a shareholder is only in the 25% individual income-tax rate, they will still have an effective tax rate of 42%, way too high to justify! Note that, at time of writing (and since 2015), the self-employment tax (when required to be paid) must be paid on the first $118,500 of "combined wages, tips, and net earnings;" note that the business will still be responsible for 2.9% Medicare tax on all self employment income (including all income about $118,500). [cites directly below]. See Self-Employment Tax (Social Security and Medicare Taxes), IRS, https://www.irs.gov/businesses/small-businesses-self-employed/self-employment-tax-social-security-and-medicare-taxes (last accessed Jan. 21, 2018); see also Tony Nitti, S Corporation Shareholder Compensation: How Much Is Enough?, THE TAX ADVISOR (Aug. 1, 2011), https://www.thetaxadviser.com/issues/2011/aug/nitti-aug2011.html#fnref_6. --------------------------|Self-Employment Tax Implications of Operating a S-Corporation|----------------- Forming an S-Corporation instead of an LLC offers many tax benefits for potential mining businesses. For example, S-Corporations offer the same beneficial tax pass-through treatment as LLCs. S-Corporations also offer the ability to AVOID ANY SELF-EMPLOYMENT TAX WHATSOEVER (in theory)!!!!!!! DISTRIBUTING INCOME S-Corporations have three main ways of distributing income: (1) employee salaries and payments to other creditors; (2) expansion / improvement expenses; and (3) making distributions to shareholders. EMPLOYMENT TAXES It is generally disadvantageous to pay yourself a salary when running an S-Corp. because salaries come with concomitant payroll tax requirements (the payroll tax is in place of a self-employment tax). Generally, shareholders prefer receiving distributions because no payroll tax is imposed on such distributions. Furthermore, these distributions are often tax free events if the shareholder has a positive basis in the corporation in excess of the amount of money being distributed to the shareholder. Rev. Rul. 59-221, 1959-1 C.B. 225 holds that a shareholder’s undistributed share of S corporation income is not treated as self-employment income. BASIS As a shareholder receives tax free distributions, their basis decreases dollar-for-dollar measured against tax-free received. Once a shareholders basis is zero, they will owe taxes on any additional income earned that year. Shareholders will pay long-term capital gain rates (in most instances) on distributions in excess of the shareholder's basis in the S-Corporation. ------------------------|SHAREHOLDERS PERFORMING SERVICES FOR THE CORPORATION|------------------ S-Corporation employee shareholders (i.e., a shareholder who also performs employee-like functions for the S-Corp) MUST be paid a "REASONABLE SALARY" for the performance of "SUBSTANTIAL SERVICES." For years, there was very little guidance on the meaning of "reasonable salary" or "substantial services." Luckily, we now have a much better idea of what these terms mean. For a great overview of case law and administrative rulings governing these issues, check out this article (also cited above) entitled S Corporation Shareholder Compensation: How Much Is Enough? (written by a CPA, MST). Essentially, within the context of a cryptocurrency mining business, your clients can avoid employment taxes (in most cases) because there is very little your clients will be doing that would qualify as substantial services. The term "substantial services" has been interpreted to require a fair amount of work (case law examples often talk about someone working for 35 hours a week, 52 weeks a year as constituting "substantial services"). Running a small to medium scale mining business is a fairly barebones operation. ---------------------------------|Fundamentals of Running a Mining Business|--------------------------------- STARTING UP Most mining operations require only the following startup materials: (1) mining hardware; (2) internet connection; and (3) adequate power source. These are the minimum components required for a mining business. Medium to large scale mining operations will likely also require some sort of separate area (i.e., signing a commercial lease) to put the mining hardware as it can get quite loud with $50,000 or more of equipment running on a non-stop basis. The mining business operator need only set up his mining hardware once and maybe troubleshoot occasionally or add/upgrade a machine. While setting up a miner can sometimes be a pain in the rear, it seldom takes more than a couple hours (keep in mind, this estimate is for businesses using commercial ASIC miners; people building their own miners warrant special considerations due to extreme time commitments required for such build-outs). PRINCIPAL FUNCTIONS As the principal function of the business is to solve transactions with complex hashing functions only solvable with specific computerized technology, the other duties associated with running a mining business are largely administrative, can be easily automated, and require only minimal supervision and monitoring. These other duties include: (1) sending mined coins from the mining pool to their wallet; (2) recording the value of a mined coin at the time it is mined (or transferred from the mining pool to the miner's business wallet if done on a consistent incremental basis); (3) keeping accurate financial records; (4) paying overhead costs; (5) occasionally logging into mining pool or miner IP address to ensure miner is running properly; (6) occasionally research new equipment for future purchases; and (7) make occasional but simple business decisions regarding whether to reinvest profits or distribute them to shareholders. TOTAL HOURS WORKED (WEEKLY BASIS) In the author's experience (running a very small three miner mining business), the average amount of time it takes to get a commercial ASIC miner running and to join a mining pool is about one hour of research and three hours of tinkering (and this was for someone with little previous experience in such matters) for a total of four hours per miner, plus or minus two hours depending on the type of miner and person. In terms of the other tasks associated with running a mining business, the author estimates that a total of roughly 20 hours per year is the maximum amount of work required to operate a small mining business. A medium-sized mining business in a commercial building should expect to spend between 10 and 50 hours per year performing employee-like tasks. A large-scale mining operation's employee-like annual hour requirements will vary substantially depending on the business owners' automation and efficiency skills but may reasonably range anywhere between 10-200 hours. Looking at the above numbers, regarding hours spent performing employee-like tasks, it is relatively simple to figure out if the shareholders of a mining business may end up performing substantial services (see S-Corp info in section above) for the corporation. For small businesses, such as mine, the mining operator may only spend a maximum of 0.3846 hours per week (20 hours per year divided by 52 weeks) working on employee-like tasks. It is safe to assume 0.3846 hours per week does not constitute "substantial services." As such, no reasonable salary need be paid to the shareholder performing this amount of work. For medium-sized mining businesses, the average amount of hours worked per week may range (based on 10-50 hour annual estimate provided above) between 0.1923 hours per week and and 0.9615 hours per week (# of hours per year divided by 52 weeks). Once again, it is safe to assume that 0.9615 hours per week (the highest end of the average) does not constitute "substantial services." As such, no reasonable salary need be paid to the shareholder performing this amount of work (especially if this amount of work is spread out over multiple shareholders). For large-scale mining businesses, a special evaluation will be necessary as setup may require a substantial amount of upfront effort and may skew the number of hours being worked. Additionally, it is possible for the amount of employee-like annual hours to vary substantially year-to-year which would cause the corporation's employment tax liabilities to vary accordingly. If we assume that the 10-200 hour estimate provided above is reasonable, we can calculate an average weekly hourly output of between 0.1923 hours per week and 3.84 hours per week (# of hours per year divided by 52 weeks). If a single employee is performing 3.84 hours of work per week, it is possible this constitutes "substantial services" when performed on a consistent basis over a continuous 52-week period. Contra Davis v. United States, No. 93-C-1173 (D. Colo. 1994) (holding that an average work week of 12 hours per week does not constitute substantial services). That said, it is entirely possible that 3.84 hours per week may fall well below the standard established by Radtke v. United States, 712 F. Supp. 143 (E.D. Wis. 1989) (distinguished on other grounds) (holding "where the corporation’s only director had the corporation pay himself, the only significant employee, no salary for substantial services . . . [h]is ‘dividends’ functioned as remuneration for employment."). As always, do your own research and advise your clients accordingly. The sources identified in this article should steer you in the right direction. Keep in mind that hiccups happen in business, and sometimes, a mining business may require long and consistent employee-like working hours by the shareholder-operator (i.e., in the event of unexpected problems). In these cases, the general principles elucidated above become muddled. As hours increase in an upward fashion, the more likely it becomes that a shareholder may need to be paid a "reasonable salary." Make sure your client is aware of this and have them call you if they anticipate working substantially more hours than expected in any given year. Should your client encounter an unexpected and substantial increase in weekly hourly requirements, one possible option to avoid incurring employment tax liabilities is to break up the total amount of work among as many shareholders as possible to keep individual hours low. Please note that the IRS may take umbrage at this sort of gamesmanship and audit your client (please note that I have not researched this tax position; it is possible existing case law or Treasury Regulations already explicitly allow or disallow this; as always, do your own research). Davis v. United States, No. 93-C 1173 (D. Colo. 1994) (pertains to hours worked and duties performed) One case, Davis v. United States, No. 93-C-1173 (D. Colo. 1994), provides strong support for the position that S-Corporation shareholder mining operators, in most instances, are unlikely to be considered to have provided substantial services requiring reasonable compensation. In Davis, the taxpayer is a S-Corporation shareholder who performed "part-time clerical duties for the company, including paying bills, submitting invoices, making bank deposits, and communicating with independent contractor truck drivers." Ms. Davis also made business decisions for Mile High and took a few business trips. Ms. Davis was not paid a salary for her performance of these duties. Rather, Ms. Davis was paid in shareholder distributions. The IRS argued that such shareholder distributions were improper as the income received should have been classified as salary income as it was actually compensation for performance of substantial services. Davis held for the taxpayer voiding the IRS's imposition of employment taxes by holding that such taxes were assessed in a manner that was arbitrary and capricious. If Davis can be reasonably relied on (make your own judgment), most S-Corporation mining business shareholders will not be required to pay themselves a salary. Figure out your facts and apply the information above accordingly!
Now Accepting Bitcoin New Age Media Management, a New York City-based management firm, is betting on Bitcoin, and plans to accept the crypto-currency beginning March 14. Though some might question the move given Bitcoin's current spate of bad press, New Age founder Adam Lopez has no qualms about taking the crypto-currency, which is unregulated, has no central bank and has fluctuated wildly since the first Bitcoins were issued about five years ago. "It's breaking into a lot of merchant circles very quickly and we wanted to be the first in the entertainment space to accept it," Lopez told Pollstar. "No one has really come forward saying they'll accept this for everything from artist commissions to consultation payments to anything we deal with across the board. "We pride ourselves on being very tech forward. This is something our team has been researching for eight months to a year - watching prices, the stock as it rises and falls, and we felt like right now, despite it getting a little bad press recently, was the right time to make it public." The bad press stems from news that one of the most prominent exchanges for Bitcoin trading - the Japan-based Mt. Gox - announced it was filing for bankruptcy last month after about 850,000 Bitcoins valued at more than $400 million disappeared from its digital coffers. In a news conference, Mt. Gox CEO Mark Karpelès explained the exchange had been hacked, and "there was some weakness in the system, and the Bitcoins have disappeared. I apologize for causing trouble," he said, according to the Wall Street Journal. Another Bitcoin bank, Flexcoin, called it quits March 2, announcing on its site, "Flexcoin was attacked and robbed of all coins in the hot wallet. The attacker made off with 896 BTC. . As Flexcoin does not have the resources, assets, or otherwise to come back from this loss, we are closing our doors immediately." Elsewhere, Autumn Radtke, the CEO for virtual currency exchange First Meta, was found dead in her Singapore home in what's been reported as an apparent suicide. Bitcoin has taken hits previously. After the FBI shut down online black-market site Silk Road in October 2013, seizing 144,000 Bitcoins, the value of the crypto-currency plummeted. It has since recovered and many have called for increased regulations, which Lopez thinks could eventually help legitimize the virtual currency. But it's also going to take buy-in from huge e-commerce companies such as the Amazons of the world before Bitcoin might gain wide acceptance. New Age Media Management's interest was piqued through the entertainment investment space and its dealings with venture capitalists. "You have the Winklevoss twins, people like Fred Wilson, and Google ventures who have all invested $30 or $35 million apiece into this venture," Lopez said, adding it's important to separate the currency from the technology as they're investing in "the technology of it. That's really where the money is - investing in the technology of this being accepted and getting merchants on board." Overstock.com is one such merchant. The company announced in January it would accept the virtual currency and said March 4 it expects Bitcoin sales to reach $10 million or $15 million this year, up from the $5 million it had expected, the WSJ reported. Richard Branson's Virgin Galactic has also backed Bitcoin for its commercial space flights. The Winklevoss twins, coincidentally, announced March 5 they'd booked their Virgin Galactic flights using the crypto-currency. Aside from the potential investment aspects of Bitcoin, Lopez noted his company could save thousands on fees by accepting the virtual currency. "The transaction fees are incredibly lower," he said. "Sometimes you'll have a 3 or 4 percent transaction fee if you go through somebody like PayPal or a credit card where as with Bitcoin you're looking at something like half a percent. That makes all the difference when you're doing transactions in the tens of thousands of dollars and saves you that much more money." It's an idea that makes sense, and just one reason Lopez is so confident about accepting the crypto-currency. "Bitcoin is definitely in the infancy stages so it's going to fluctuate a lot in price and in interest but we feel like a lot of our artists and the VCs we work with are very excited about the concept," he said. -Dana Parker-McClain
With regard to Ms. Radtke, her team, and Japanese court filings suggesting her connection to finding Gox bitcoin, not a shred of proof has been produced. And that which can be asserted without ... The CEO of a Bitcoin exchange firm First Meta was found dead in her apartment in Singapore last week. She was 28. Local media reports suggest Autumn Radtke may have committed suicide; however, an official cause of death has not been declared. An investigation has been launched into the "unnatural" death, a police spokesman told Reuters Wednesday.. R.I.P. Autumn Radtke 28 yrs CEO of First Meta ... Autumn Radtke, the 28-year-old CEO of the Bitcoin exchange First Meta, was found dead in her home in Singapore.According to the Daily Mail, local media are reporting that police suspect the cause ... Autumn Radtke war Chefin einer Bitcoin-Handelsplattform. Nun ist die US-Amerikanerin tot. Sie nahm sich vermutlich das Leben, nachdem die grösste Bitcoin-Börse Insolvenz anmeldete. Ein weiteres Drama erschüttert die Finanzbranche: Autumn Radtke († 28), die Chefin der Bitcoin-Plattform First Meta, ist unter zweifelhaften Umständen ums Leben gekommen, berichtet die ...
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