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_Beagle48(Newbie)Newbie
18 July 2021

Hi.

I acquired SingularityNET (AGI) tokens in late 2019. In late May 2021, SingularityNET replaced the ERC20 AGI token with the ERC20 AGIX token on a 1:1 basis. That is, my AGI tokens were permanently frozen and I received the replacement token, AGIX, at a ratio of "1 AGIX : 1 AGI".

AGIX is a hard-fork of AGI. AGIX provides the same functionality that AGI did, plus cross-chain capabilities. The swap did not increase the original asset value. More information can be found here: https://blog.singularitynet.io/singularitynet-phase-ii-launch-sequence-activated-agi-token-to-be-hard-forked-to-10ede4b6c89

Given that AGI was replaced with AGIX, is AGIX considered to be the original AGI token for tax purposes? Did a CGT event occur during the token replacement?

The reason I am asking is because in July 2021, I disposed of all of my AGIX for ETH and BTC, thus triggering CGT events. Given that I purchased AGI in 2019 and held onto it for over a year, I would like to know if my disposal of AGIX in July 2021 is eligible for the 50% long-term capital gains discount? I have assumed it was, based on advice in these links:

https://community.ato.gov.au/t5/Cryptocurrency/Tokens-redenomination/td-p/137703

https://community.ato.gov.au/t5/Cryptocurrency/Token-migration-and-cashing-out/td-p/140636

https://community.ato.gov.au/t5/Cryptocurrency/Token-migration/td-p/137166

https://community.ato.gov.au/t5/Cryptocurrency/Is-a-1-1-token-swap-migration-from-erc-20-to-mainnet-token-a/td-p/142091

This is a loose summary of events that occurred:

Late 2019: AGI purchased for approx $25,000

May 2021: AGI is replaced with AGIX (AGI was valued at approximately $220,000-$360,000 in days prior to the replacement)

July 2021: AGIX sold for approx $240,000

There are two scenarios that I can foresee:

Scenario 1: AGI-AGIX replacement is not a CGT event. AGIX is considered the same as the original AGI token. Therefore:

  1. Proceeds of AGIX less cost basis of AGI/AGIX: $240,000 - $25,000 = $215,000 capital gain.
  2. 50% discount can be applied to $215,000 capital gain as AGI/AGIX was held for over a year.

Scenario 2: AGI-AGIX replacement is a CGT event. AGIX is not considered the same as the original AGI token. AGIX cost basis is $0. Therefore:

  1. AGI cost basis is written off at time of replacement: ($25,000)
  2. Proceeds of AGIX less cost basis of AGIX: $240,000 - $0 = $240,000 capital gain.
  3. Net capital gain: $240,000 gain - $25,000 loss = $215,000
  4. 50% discount cannot be applied to $215,000 because AGIX was only held for approx 1 month.

I purchased the original AGI asset with the intention of applying the long-term 50% CGT discount in the future, and I hope that the token replacement has not derailed this strategy.

I plan to engage a suitably experienced cryptocurrency accountant to prepare my return, but I wanted to consult here first.

Kind Regards.

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1,240 views
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AriATO(Community Support)Community Support
19 July 2021

Hi @Beagle48

We don't have specific information on our website for crypto in particular but similar to shares, units and options this may qualify for a rollover.

Theres no CGT event for replacing the old version of an asset with a new version and the CGT event happens when the new assets are sold. In the event a rollover applies, you can still use the discount method as long as the period of ownership of both the new and old assets was at least 12 months.

You can read more about Rollovers on our website and if you want written confirmation about your particular circumstances you can contact our Early engagement team for further advice

All replies

Most helpful reply

AriATO(Community Support)Community Support
19 July 2021

Hi @Beagle48

We don't have specific information on our website for crypto in particular but similar to shares, units and options this may qualify for a rollover.

Theres no CGT event for replacing the old version of an asset with a new version and the CGT event happens when the new assets are sold. In the event a rollover applies, you can still use the discount method as long as the period of ownership of both the new and old assets was at least 12 months.

You can read more about Rollovers on our website and if you want written confirmation about your particular circumstances you can contact our Early engagement team for further advice

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