“A flat rate is the right call for the wrong reason”
You support the flat rate proposal. Why the reservation?
I support it because the tiered alternative is unadministrable, not because a flat rate is theoretically preferable. Establishing an acquisition date across self-custodied wallets and offshore venues is not realistically possible, so a rate that does not depend on one is the only workable option. That is a concession to reality, and it should be described as such.
What should the consultation have addressed?
Cost basis. The paper is silent on methodology, and the difference between first-in-first-out and weighted average is material for anyone who has accumulated over several years. Taxpayers will adopt whichever is favourable and the Board will dispute it later, which serves nobody.
Does this settle the matter?
No. It settles the rate. It leaves open basis, the treatment of staking and lending income, and what happens on a chain reorganisation. Those will each need their own guidance.