Clinton Donnelly, CEO of Crypto Tax Audit, stated that many U.S. users have not reported their cryptocurrency taxes because they are afraid that the IRS will modify regulations after they submit their tax returns. The IRS has the discretionary power to apply laws retroactively or retrospectively interpret them. It is reported that Clinton Donnelly is also an expert in calculating capital gains from cryptocurrency.

In the IRS's notice on March 25th, the existing general tax principles regarding transactions using virtual currency were described. In this update, also known as Notice 2014-21, the IRS stated that the general tax principles applicable to property transactions will apply to transactions using virtual currency. Although this notice did clarify the IRS's position on cryptocurrency transactions, Clinton Donnelly stated that it lacks the legal binding force of regulations. Prior to this update, the IRS had not expressed an opinion on the taxation of cryptocurrency.