How Crypto Mining Companies Use Smart Arrangements to Unlock Big Profits

FinTax

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Jan 4, 2025
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With the blockchain tech wave surging, crypto mining companies have become a hot spot for global investments. In this digital gold rush, the US is quickly rising as the absolute top spot for global crypto mining, thanks to its unique advantages—friendly regulatory environment, cheap energy costs, and the trend toward local manufacturing driven by geopolitics. Data from the White House Office of Science and Technology Policy shows that as of 2022, the US holds over 37.84% of the global Bitcoin mining hash rate, ranking first in the world, while attracting dozens of listed companies to jump in, expanding the crypto mining industry map at an unprecedented speed.

However, beneath this booming scene, crypto mining companies that mine in the US and directly sell their cryptocurrencies are facing a double tax burden. The cryptocurrencies earned from mining need to be reported for income tax at their fair market value when obtained; and when sold later, any appreciation in value relative to the original acquisition cost is subject to additional taxation under capital gains regulations. This layered tax burden objectively brings heavy tax pressures to crypto mining companies. But through proper tax arrangements, these companies can totally reduce large tax amounts in a legal and reasonable way, turning what was a tax burden into extra competitiveness.

US, Singapore, Hong Kong: A Comparison of Capital Gains Tax Systems

Tax policies for cryptocurrencies vary across different jurisdictions. The US treats cryptocurrencies as property, and gains from selling or exchanging them are subject to capital gains tax. For corporations (default C-corp, same below), asset appreciation is taxed at a flat 21% federal income tax rate, while individuals pay different rates based on holding period: short-term holdings (less than a year) are taxed at ordinary income rates up to 37%, and long-term holdings (over a year) get preferential rates of 15% to 20%. Whether it’s occasional selling for cash or frequent trading or business operations, US tax law treats it the same—if there’s a taxable transaction with profit, you have to report and pay tax. This “tax on every profit” system puts significant tax pressure on US-based crypto investors and miners.

In comparison, Singapore and Hong Kong have much friendlier capital gains tax policies. Both places currently don’t tax capital gains from non-regular investments in cryptocurrencies for individuals and corporations. That means as long as the transactions are seen as capital investment gains, investors don’t have to pay tax on the asset appreciation, truly enjoying zero tax benefits for long-term holdings. Of course, if the taxpayer’s actions are viewed as frequent trading or business operation, they need to pay corporate (or personal) income tax on the profits. Singapore’s tax authority taxes at about 17% for corporate income tax, and individuals pay progressive rates from 0% to 24% based on income levels; Hong Kong taxes profits from regular crypto trading at 16.5% for companies and 15% for individuals. While frequent traders still pay taxes, compared to the US’s top 37% personal rate or 21% federal corporate tax, Hong Kong and Singapore’s rates definitely have stronger competitiveness.

Table: Comparison Table of Capital Gains Tax in the US, Hong Kong, and Singapore

Country/Region
Corporations
(normal investment)​
Corporations
(frequent trading or business operation)​
Individuals
(normal investment)​
Individuals
(frequent trading or business operation)​
The US
21% Federal tax rate​
Long-term holding: 15%-20%
Short-term: Up to 37%​
Hong Kong
No capital gains tax​
16.5%​
No capital gains tax​
15%​
Singapore
No capital gains tax​
17%​
No capital gains tax​
0%-24% (progressive rates)​


Using Singapore as a Bridge: One Option for US Mining Companies

Based on the tax differences across jurisdictions, a tailored tax arrangement plan has emerged for US crypto mining companies. Take a US-based Bitcoin mining farm company as an example: it can set up a cross-border structure to legally ease the tax pressure from cryptocurrency appreciation. The company can establish a subsidiary in Singapore, first sell the daily mined Bitcoins to this subsidiary at fair market price, then have the subsidiary sell them to the global market. Through this “internal first, external later” transaction setup, the US parent company only needs to pay corporate income tax on the initial mining earnings, while the Singapore subsidiary’s profits from Bitcoin appreciation can be exempt from capital gains tax.

The tax-saving effect of this structure is obvious. Since Singapore doesn’t levy capital gains tax on gains from long-term holding and selling crypto assets, the subsidiary’s price difference profits from selling Bitcoins barely need to be taxed locally. In contrast, if the US company directly holds the Bitcoins until they appreciate and sells them domestically, that appreciation gain would be hit with up to 21% federal long-term capital gains tax. By relocating the price appreciation of cryptocurrencies to a jurisdiction exempt from capital gains tax, the mining company’s overall tax burden drops significantly, freeing up more funds for reinvestment or shareholder dividends, thus unlocking bigger profit spaces for the business.

Risk Reminder: Multiple Considerations for Tax Arrangements

It’s important to stress that any tax arrangement must be done within a legal and reasonable framework, and to achieve the tax benefits in the above plan, transaction pricing and business substance must be carefully arranged to ensure compliance with local requirements. For example, on one hand, US tax law has strict transfer pricing rules for transactions between related entities, requiring all related-party deals to be at arm’s length market prices, or else face serious tax audits and penalty risks. On the other hand, Singapore’s tax authority will judge based on transaction frequency, purpose, and other specifics whether the subsidiary’s Bitcoin sales gains are capital gains or business income. Only if recognized as investment-type appreciation gains can they enjoy tax exemption. Therefore, implementing this cross-border structure needs support from professional firms’ tax planning and compliance operations to ensure the plan achieves tax savings without triggering compliance risks.

Conclusion

This article shares just a basic tax arrangement idea. In actual operations, factors like the crypto mining company’s business model, shareholder structure, state laws, and international tax treaties will all influence the design of the optimal plan. Tax arrangements aren’t one-size-fits-all formulas but need to be “custom-tailored” to the company’s specific situation. The FinTax consulting team provides one-stop financial and tax solutions, helping companies boost compliance levels and financial efficiency, with rich practical experience in handling complex cross-border financial and tax issues, serving many Crypto US-listed companies and multinational enterprises. If you want to further discuss and implement a tax plan suited to your needs, feel free to contact us anytime.

(Disclaimer: The above content is for general reference only and does not constitute any legal or tax advice.)