A protocol replacing an old token contract with a new one and asking holders to swap v1 tokens for v2, usually one-for-one.
A one-for-one migration of the same asset by the same issuer is commonly treated as a non-taxable change in form, with basis and holding period carried over. A migration with a changed ratio, a different asset, or added rights looks more like an exchange. Document which it was.
Usually treated as a non-taxable migration when it is one-for-one from the same issuer. Ratio changes or different economics make it an exchange.
Source: No IRS guidance as of September 2026; IRS Notice 2014-21 (property treatment)
Last reviewed September 18, 2026. Tax rules change; confirm current law before acting.
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