Stablecoin Compensation Primer

About Toku

Toku is a leading platform for managing token compensation and global employment in 100+ jurisdictions, purpose-built for crypto-native teams. Toku is trusted by industry leaders like Matter Labs, zkSync, Eigen Layer, Polygon, Near, Scroll, Protocol Labs, Mina, and many more.

The authors wish to thank the BDO Digital Assets team, Fenwick’s Blockchain Practice, and Orrick’s Blockchain Practice for their contributions to this primer.

The views expressed in this primer are for informational purposes only and should not be construed as investment, legal, or tax advice. Readers are strongly encouraged to consult qualified legal, tax, and financial professionals regarding their specific circumstances.

For further details, please refer to the section entitled “Legal Information and Disclaimer” at the end of this document or reach out to Ken O’Friel (ken@toku.com) or Dominika Stobiecka (dom@toku.com).

Copyright © 2024 Toku. All rights reserved.

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Introduction

Global payroll represents one of the world's largest and most inefficient financial systems. The global payroll market reached $99 billion in 2023 and is expected to hit $134 billion by 2028¹, yet the underlying infrastructure remains virtually unchanged for decades. This antiquated system processes over $48 trillion in annual wages for 1.74 billion salaried workers globally through a fragmented network of local providers, banks, and regulatory frameworks.²

The current system's inefficiencies are stark: cross-border payments can take several days to settle³ and incur 6–7% transaction fees⁴, while multinational companies must manage dozens of local payroll providers and bank relationships. Each jurisdiction requires separate systems, compliance processes, and reconciliation workflows, making real-time global payroll operations impossible. Companies lose billions annually to unnecessary fees, trapped working capital, and operational overhead.

Stablecoins present a fundamental solution to these systemic problems. Their 24/7 instant settlement capability eliminates traditional banking delays and intermediary fees. Instead of maintaining multiple local bank accounts and operating in multiple currencies, companies can operate from a single pool of stablecoin liquidity with complete transparency and automated reconciliation.

Why Now?

Market conditions now favor widespread adoption. The total stablecoin market cap has grown to $160 billion, demonstrating technological maturity. Regulatory frameworks for digital assets are slowly but steadily crystallizing globally. Blockchain companies are already proving the model's viability using USDC, USDT, and DAI to disburse base salaries and bonuses. Critical infrastructure components—institutional custody, compliance tools, and fiat on/off ramps—are battle-tested and available.

Our analysis indicates that global payroll transformation through stablecoins will occur in distinct phases. Crypto-native companies are leading adoption, establishing operational blueprints, and testing compliance frameworks. Mainstream companies are expected to follow with cross-border implementations drawn by demonstrated cost savings and operational efficiencies. By 2030, network effects should drive broader market adoption as the infrastructure matures and regulatory clarity improves.

This primer aims to provide a clear framework for understanding stablecoin compensation—specifically stablecoin payroll. It covers the technical basics, regulatory aspects, and practical steps companies can take to transition from traditional payroll systems to blockchain-based solutions.

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Understanding Stablecoin Payroll: Beyond Simple Token Transfers

Stablecoin payroll represents a hybrid system where companies compensate employees using blockchain-based tokens pegged to fiat currencies while maintaining traditional payroll compliance. This system combines the efficiency of blockchain technology with the regulatory requirements of traditional employment: tax withholdings, social security contributions, benefits administration, and compliance with local labor laws. Unlike contractor payments, employee payroll requires sophisticated infrastructure to handle stablecoin transfers and complex compliance operations across multiple jurisdictions.

The market opportunity is substantial, with U.S. employee wages ($11.1 trillion annually) exceeding contractor payments ($363.5 billion) by a factor of over 30.⁵ This scale demands a robust infrastructure to process regular payment schedules, calculate withholdings, manage employer contributions, and ensure regulatory compliance while leveraging blockchain rails for final settlement. Cross-border employment adds further complexity, requiring systems that can navigate tax treaties, work location requirements, and jurisdiction-specific regulations—for instance, managing U.S. state and federal withholdings for temporary workers while executing salary payments in stablecoins.

While these operational challenges have historically limited adoption to simpler contractor payments, the sheer size of the employee payroll opportunity—more than 30 times larger than the contractor market—suggests that solving these infrastructure challenges could unlock transformative value for employers and employees.

For employees, particularly in emerging markets, the system offers significant advantages: preservation of purchasing power through dollar-pegged assets in high-inflation environments, instant settlement versus traditional 2–3 day delays, reduced cross-border fees, access to dollar-denominated yield opportunities typically unavailable in local markets, and financial inclusion and security through internet-only access requirements. These benefits make stablecoin payroll valuable for global workforces seeking stable currency exposure and enhanced financial opportunities.

The Need For A Stablecoin Native Payroll Provider

The infrastructure challenge creates a notable gap in the market. Traditional payroll providers, EORs, and PEOs have struggled to integrate blockchain capabilities, while crypto-native companies often lack the necessary compliance expertise. Specialized platforms like Toku have emerged to bridge this divide, combining stablecoin payment rails with comprehensive payroll compliance capabilities. These systems maintain traditional payroll functions—regular scheduling, tax withholding, reporting—while innovating on the final payment layer, delivering net compensation in stablecoins after handling all required fiat-denominated obligations.

This evolution represents a significant advancement in global payroll infrastructure, offering particular benefits for cross-border workforces while maintaining full regulatory compliance. Rather than operating as a parallel system, stablecoin payroll integrates blockchain efficiency with traditional financial frameworks, reshaping how global compensation is delivered and managed.

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Why Haven't Stablecoins Been Widely Adopted For Payroll?

Despite the clear theoretical benefits of stablecoin payroll, widespread adoption has been limited primarily to crypto-native organizations, particularly Decentralized Autonomous Organizations (DAOs). These entities, operating entirely on-chain and often without traditional bank accounts, have successfully pioneered stablecoin payroll while maintaining tax compliance—demonstrating the model's viability. However, mainstream adoption faces several key barriers.

The fundamental challenge is the current disconnect between on-chain and traditional business operations. While stablecoins offer compelling advantages for final settlement, most business activities, revenue generation, and especially tax obligations remain firmly rooted in the fiat system. Tax authorities require payments in fiat currency, regardless of how compensation is delivered. This creates additional complexity for businesses managing both systems simultaneously, often negating the efficiency gains from stablecoin adoption.

Regulatory uncertainty adds another layer of complexity. Questions remain around the application of fair value accounting standards to stablecoins. While these standards apply to volatile cryptocurrencies like Bitcoin, their application to stablecoins—particularly those backed by different types of assets—lacks clarity. This uncertainty raises important questions about potential gains or losses triggered by stablecoin payments and their impact on withholding calculations. However, these concerns may be mitigated when payments are processed through specialized payroll providers.

However, the trajectory of adoption might follow different patterns. Rather than waiting for the broader crypto economy to drive stablecoin payroll adoption, the reverse might occur: the practical benefits of stablecoin payroll could accelerate the mainstream integration of blockchain technology in business operations. The clear advantages of global workforce management—particularly in emerging markets—make payroll a compelling entry point for blockchain adoption.

Our conversations with hundreds of potential customers reveal that the benefits must significantly outweigh the operational complexity to drive adoption. Currently, this value proposition is strongest for organizations already operating substantially on-chain, where stablecoin treasury management and payments align naturally with their business model. As companies experience these advantages in payroll operations, they may be more inclined to explore other blockchain applications, creating a natural pathway for broader crypto adoption in traditional business contexts.

This suggests that stablecoin payroll could serve as a catalyst rather than a follower in mainstream blockchain adoption. The combination of clear business utility, employee benefits, and demonstrated regulatory compliance, despite remaining uncertainties, positions payroll as a potentially ideal starting point for integrating blockchain technology into traditional business operations.

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Key Considerations For Implementing Stablecoin Payroll

Legal frameworks

Organizations implementing stablecoin payroll must navigate complex, varying regulatory requirements across jurisdictions. A common regulatory constraint is the mandate for minimum wage payments to be made in local fiat currency, while allowing supplemental compensation in stablecoins. This results in a hybrid payroll model that requires systems capable of managing both fiat and stablecoin disbursements concurrently.

Tax processing and reporting

Tax compliance requires careful structuring of payroll processes. All tax withholdings and deductions must be calculated based on the total compensation value and remitted in local currency, regardless of how the net pay is distributed between fiat and stablecoins.

Beginning in January 2025 in the U.S., new broker reporting requirements may significantly affect stablecoin payroll operations⁶. Organizations will be required to file Form 1099-DA, which mandates detailed reporting of stablecoin transfers, including transaction dates, USD values, wallet addresses, and the basis for valuations used. This information must be submitted to both employees and the IRS, adhering to traditional Form 1099 deadlines.

While companies primarily using stablecoins for payroll (as opposed to facilitating third-party transfers) may qualify for modified reporting requirements, they must still maintain comprehensive records of all transfers, valuation methodologies, and conversion processes for a period of five years.⁷

Valuation and conversion

Fair market value (FMV) determination for stablecoin payroll presents unique challenges due to the dynamic nature of cryptocurrency markets. While stablecoins aim to maintain parity with their pegged currency, slight variations occur across different exchanges and time periods. Consistent, fair market value determination is essential for both payroll processing and tax reporting. In the U.S., in the absence of specific Treasury guidance, organizations typically follow these practices:

• Primary market reference: Using prices from regulated U.S. exchanges as primary reference point
• ‍Documentation requirements:‍
  
  • Timestamp of valuation
  • Sources of price data
  • Volume data supporting valuation
  • Methodology calculation
  • Any deviations from the standard methodology
• ‍Conservative approach: When faced with multiple possible valuations, using the more conservative option that could result in higher taxable income

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Employee experience

Organizations should provide employees with detailed guidance, including compatible wallet options (recommended wallets for receiving stablecoin payments), conversion methods (best practices for converting stablecoins to local currency), and tax reporting requirements (required documentation to simplify tax reporting, including payslips).

A phased rollout with an initial opt-in phase allows organizations to optimize processes before a full-scale launch for all employees. Before initiating stablecoin payroll, organizations must obtain explicit, written employee consent. This document should outline the payment structure, specifying the fiat-to-stablecoin ratio, and timing for payments. Generally, payment schedules should be synchronized with standard payroll cycles to ensure predictability and consistency for employees.

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Steps For Implementing Stablecoin Payroll

While there are variations, here are the steps for the typical setup:

1. Stablecoin custody setup:
   
   1. Custodians: Third-party services that manage the company's stablecoin assets, ensuring regulatory compliance and security
   2. ‍Multi-signature wallets: Wallets requiring multiple private keys to authorize transactions, enhancing security and reducing the risk of unauthorized access
2. Payroll calculation:
   
   1. Gross salary: The total compensation payable to each employee in both fiat and stablecoins
   2. ‍Tax withholdings: Federal, state, and local taxes, including social security deductions, are calculated based on the gross salary
   3. ‍Net payroll amount: The total amount due for employee payments, specifying the required amount of stablecoins, the type of stablecoins (e.g., USDC, USDT, PYUSD), and the wallet addresses for employee payments
3. Tax remittance: Payroll provider fulfills tax obligations by remitting the calculated tax withholdings to the relevant governmental agencies in fiat.
4. Employee payment: Following tax remittance, the company processes the remaining balance. Employees receive their net payments directly in stablecoins to their designated wallets, with any additional amounts paid in fiat as needed. For record-keeping, each employee is provided with a clear breakdown of their total compensation.
5. Payslip generation:
   
   1. Gross salary: Total earnings before deductions
   2. ‍Tax withholdings: Detailed breakdown of federal, state, local, and social security deductions
   3. ‍Net pay: The final amount paid to employees in stablecoins and/or fiat, clearly indicating the stablecoin type used
6. W-2 (or local equivalent) generation:
   – At the end of the tax year, the payroll provider generates W-2 forms for employees detailing total earnings, tax withholdings, and other relevant information. These forms are distributed to employees for tax reporting purposes, ensuring compliance with IRS regulations regarding cryptocurrency income.

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How To integrate Stablecoin Payroll With Local Payroll Providers

To integrate stablecoin payroll with local payroll providers who do not accept or are unfamiliar with cryptocurrency, a crypto-native compensation provider like Toku would facilitate stablecoin payments. Toku integrates with and helps local payroll providers accurately reflect stablecoin payments on local payslips and then in turn pay governments proper withholding amounts in local currencies.

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How To Manage The Employer And Employee Withholdings With Stablecoin Payroll

When a company pays employees in stablecoins, a portion of the compensation must be withheld and paid to the government for taxes and social security payments, both for the employee and employer.

However, governments almost always need to be paid in local fiat currency. So, to operate stablecoin payroll, you must be able to pay the necessary taxes and social security payments in fiat currency. To pay those withholdings in fiat currency, you can do either:

• Sell to cover: Send your stablecoins to an off-ramp to convert them to USD and then to the local fiat currency at the time of payment to the employee to immediately fund the withholding payments to the government

• Treasury management: Sell and hold some portion of your treasury in the local fiat currency necessary to make the fiat withholding payments of the employee and the employer. Though the timing of selling the stablecoins would be somewhat irrelevant due to the stablecoin's peg to fiat currency, treasury management would still be a function to ensure enough fiat remained in reserve for payroll withholding purposes.

• Investment funds or operating profits: This is very similar to treasury management, except that instead of selling stablecoins to have enough fiat reserves, you would use some portion of the fiat investment funds or operating profit to pay for the fiat-based withholding taxes.

• Crypto Native EOR/PEO or Payroll Provider: Use a crypto-native EOR/PEO or payroll provider who can manage the stablecoin conversion in the process of paying the government and some portion to workers in fiat.

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How To Manage The Holding Of Stablecoins With Custodians And Multi-sigs

Your company can hold stablecoins like any other cryptocurrency by either self-custodying them in your digital wallet or with a crypto custodian like Anchorage, Fireblocks, or Coinbase. Those options may use one or more signatories for security.

A crypto-native compensation services provider like Toku can adapt to your preferred method of holding and managing your stablecoins, whether with a custodian or a multi-sig digital wallet. This provides a high degree of flexibility not only in the process of custodying the stablecoins but also in the range of blockchains to hold the stablecoins that support your preferred stablecoins.

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Smart Contracts For Stablecoin Compensation

We often get asked about using smart contracts when holding and remitting stablecoins and other cryptocurrencies for compensation. While smart contracts have tremendous potential for many specific uses, given the flexibility and high degree of security and privacy required for compensation purposes, we do not think they are the right tool for stablecoin payroll related payments at this time. This could change as blockchains and smart contract technology continue to evolve.

For example, while smart contracts have faced vulnerabilities and been hacked, multi-sig wallets have a strong track record of securely storing cryptocurrencies. Additionally, payroll compensation often requires quick adjustments, whether initiating or halting payments as details change. Managing these changes is typically more efficient with multi-sig wallets than with smart contracts.

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Regulatory Compliance Concerns

As discussed above, workers receiving stablecoins still need to pay their expenses, bills and taxes in fiat for the most part, so considering the stablecoin-to-fiat conversation (“off ramp”) must be part of adopting stablecoin payroll.  

There are three levels where stablecoins can be converted to fiat for stablecoin, or vice versa, compensation purposes:

• At the company level: Where the net portion to be paid in stablecoins can be remitted to the worker by the company or EOR/PEO, and other amounts desired in fiat remitted to the EOR/PEO or payroll provider who passes them onto the worker or tax agencies 
• At the EOR/PEO or payroll provider level: Where the company would send the necessary stablecoins to the EOR/PEO or payroll provider against an invoice, and the EOR/PEO or payroll provider would convert the necessary stablecoins to fiat in the amounts desired as necessary for paying the tax agencies, and the amount of fiat the worker desired. The worker may need to convert additional stable coins to fiat once they received part of their compensation in stablecoins, but the worker could rely on the compensation provider to provide at least part of the worker’s compensation in fiat without the worker needing to convert the stablecoins to fiat on their own each pay period 
• By the worker: Where the amount of compensation would be paid to the worker entirely in stablecoins, net of any withholding taxes, and the worker would be responsible for converting the stablecoins as needed for the worker’s own purposes.  

We note that stablecoin companies combined are the 16th largest owner of US debt in the form of bonds. We believe that the US Congress has a vested interest in seeing the success of stablecoins, especially with multiple failed bond auctions in the past 14 months and we will see a change in regulatory stance from the US Congress in the coming months.  

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What Are The Considerations For Money Transmission Laws And Regulations When Using Stablecoins

The US federal definition of money transmission revolves around two prongs of moving money between (a) different people or (b) different places.⁸ US states and other countries have separate definitions of money transmission that must be considered. When moving money between people or places, you may be deemed a money transmitter that needs to be registered with FinCEN and licensed in certain states where you receive or send money or other value that substitutes for money like cryptocurrency, unless you qualify under an exception to money transmission.⁹ Those exceptions broadly are:

• Banks: Banks are exempt from money transmission licensing requirements because they are regulated for this purpose in other ways.

• Payment processors: This includes companies whose primary business is processing payments like PayPal, Block, Moonpay or Stripe

• Payroll processors: In the US, applying state and federal money transmission laws to payroll providers is complicated. Some states explicitly carve them out, and some states explicitly consider them money transmitters. At the federal level, FinCEN has not provided guidance.

• Agents of payees: This includes companies that are moving money on behalf of companies or persons providing goods or services, like marketplaces or payroll providers

• Authorized delegates: This involves companies using an exempt entity, such as a bank or payment processor, to move money on their behalf.

Many service providers in the blockchain industry that offer the ability to send tokens on behalf of a customer are likely at risk of being considered a money transmitter. If one is using a service provider to transfer money or money equivalent, which in this case will be stablecoins on their behalf, then one must be able to rely on the compliance of that service provider under the money transmission laws.

Whether your business needs money transmission licenses is a facts and circumstances test under federal and state rules. If you are not using a service provider, this should only be determined with specific legal advice from an attorney specializing in the field.

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What Are The Considerations For Privacy When Using Stablecoins

Stablecoin payroll, while efficient and reliable, introduces significant privacy challenges due to blockchain’s transparent, immutable nature. Public visibility of transaction details, such as amounts, dates, and wallet addresses, risks exposing sensitive payroll data, potentially revealing employee salaries and financial behavior. Identity linkage further heightens this concern, as blockchain addresses, though pseudonymous, can be associated with specific individuals over time, inviting unwanted profiling or targeting.

To address these issues, employers and payroll providers can adopt privacy-focused technologies. Privacy-centric stablecoins and Layer-2 solutions, including privacy-preserving rollups, offer encryption and transaction obfuscation to shield employee details. Practices like periodic wallet rotation and off-chain data aggregation add additional privacy layers, limiting long-term traceability and keeping specific payroll information off the public ledger.

Maintaining regulatory compliance in this context, especially with GDPR, adds complexity. Solutions such as data encryption, cryptographic sharding, and private blockchains allow companies to manage privacy while adhering to compliance standards. Given the specialized nature of these needs, it’s essential to work with crypto-native providers who understand these nuances and have tailored solutions. These providers ensure both the protection of employees’ financial information and the full benefits of stablecoin payroll.

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Conclusion

Stablecoin payroll has the potential to transform compensation infrastructure globally, just like cryptocurrency promises to do. While we navigate these changes and witness their impacts on both businesses and employees in the crypto industry, our commitment remains firm: we are here to support and advance the cryptocurrency industry, continually adapting to these evolving financial paradigms of cryptocurrency.

As the stablecoin landscape continues to evolve, there is a noticeable uptick in the demand for stablecoin payroll systems among cryptocurrency businesses. However, we still need to catch up to the moment where traditional small or even large businesses might regularly utilize stablecoins for payroll. We are committed to closely monitoring these developments and are keen to see how the market's reception might shape future trends. For those intrigued by the potential of stablecoin payroll and looking to explore streamlining compensation, payments and compliance, we recommend contacting Toku. We can provide deeper insights and guidance on navigating this emerging field of stablecoin compensation.

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Appendix

Country-specific considerations for stablecoins

Each country has its own unique laws for regulating and taxing stablecoins. Here is a survey of a few countries describing their approaches:

United States

In the U.S., the IRS has stated employers are permitted to pay employees in cryptocurrency¹⁰ but it is less clear whether the payment of wages in cryptocurrency is permissible under the Fair Labor Standards Act, which provides that payments of wages to employees, including overtime compensation, must be made in cash or a negotiable instrument payable at par.¹¹ The Department of Labor has not officially opined on whether cryptocurrency is considered a “negotiable instrument payable at par” that may constitute “wages” under the FLSA. Therefore, it is prudent for employers to pay U.S. employees their wages in cash to the extent that such wages are under minimum levels set by the FLSA.

Employers must, however, comply with tax regulations by treating stablecoins as property, as the IRS has stated that for federal tax purposes, virtual currency is treated as property.¹² This means the fair market value of the stablecoins at the time of payment must be reported on Form W-2 in U.S. dollars. Employers are also responsible for withholding taxes and ensuring compliance with federal and state labor laws, including minimum wage laws.

Employers must also consider whether state laws permit compensating employees in stablecoins instead of fiat currency. States have different laws that may challenge this practice. A few examples include:

• In California, wages must be “payable in cash, on demand, without discount,”¹³ meaning that large fluctuations in the value of stablecoin between the time that payroll is processed and the time of payment to the employee could lead to violations of California state law.

• In New York, wages must be paid by cash, check, direct deposit, or payroll debit card.¹⁴ Although the New York statute does not prohibit payment by another means, it remains to be seen whether New York state courts or the New York Department of Labor will allow the payment of wages to employees in the form of cryptocurrency.

• Washington state requires that wages be provided at “no cost to the employee,”¹⁵ meaning that exchange fees incurred when wages paid in U.S. dollars are converted into a stablecoin should not be borne by the employee.

• The Texas Labor Code provides that employers should pay wages to employees in U.S. currency, by a written instrument issued by the employer that is negotiable on demand at full face value for U.S. currency, or by the electronic transfer of funds to either a financial institution account designated by the employee, or a payroll card account established by the employer. The employee may agree in writing to accept part or all of their wages in a different form.¹⁶

United Kingdom

The UK also allows stablecoin compensation, treating it as either capital gains or ordinary income depending on the situation. Tax and labor laws mandate that payments meet minimum wage requirements when converted to British Pounds. UK employers considering stablecoin payments must navigate these regulations carefully to ensure compliance, particularly as the legal landscape around digital assets continues to evolve.

India

India has seen rapid changes in its approach to stablecoins. Currently, stablecoins are legal, and compensation with stablecoins is permitted. However, employers must adhere to a stringent tax regime that includes a 1% tax deducted at source (TDS) on transactions with stablecoins in addition to taxation at ordinary income rates. This demands meticulous financial planning from employers to comply with tax laws while leveraging the benefits of cryptocurrency payroll.

Australia

Australia treats stablecoins as property for tax purposes. This classification has significant implications for payroll because it necessitates adherence to the Australian Taxation Office (ATO) guidelines, particularly concerning tax reporting and withholding obligations. Employers must convert the stablecoin value, even if pegged to the Australian dollar or another fiat currency, into Australian dollars at the time of each payment, ensuring compliance with local tax laws.

Switzerland

Switzerland is known for its crypto-friendly stance, yet employers must still navigate a complex legal framework for using stablecoins. Compensation in stablecoins is treated similar to traditional forms of payment, subject to regular tax laws. Swiss employers must ensure that the value of the stablecoins at the time of payment meets the requirements of Swiss labor laws, which include adhering to minimum wage regulations.

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Legal Information and Disclaimer

The views expressed in this document are not intended to be, and should not be viewed as, investment, legal, or tax advice. It does not constitute an invitation, recommendation, or solicitation to purchase any products or services offered by Toku or its affiliates.

Opinions expressed are current as of the publication date and are subject to change without notice. Toku assumes no obligation to update any information contained in this document. Readers are advised to consult qualified legal, tax, and financial professionals regarding their specific circumstances.

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Citations:

1. Research and Markets. (2023, August 11). Global Payroll Market (2023–2028) by Component, Type, Business Size, Industry Vertical, and Geography, Competitive Analysis.
2. International Labour Organization. (2023). Global Wage Report 2022–2023.
3. Bank of England. (2023, January 31). Cross-border payments.
4. World Bank Group. (2022, September). Remittance Prices Worldwide – Issue 43.
5. Bureau of Labor Statistics. (2023). Employment and Wages, Annual Averages 2023.
6. The reporting requirements come from the Infrastructure Investment and Jobs Act (also known as the Bipartisan Infrastructure Law), signed in November 2021. The new regulations treat companies handling digital assets like traditional financial brokers. However, the Treasury Department and IRS are still finalizing the specific implementation details and may provide modified requirements for companies using stablecoins solely for payroll purposes rather than as trading intermediaries.
7. U.S. Treasury has outlined several safe harbor provisions, including a de minimis exception for transfers under $600 annually per employee and acceptance of qualified price feeds for valuation. The requirements particularly emphasize the need for robust cost basis tracking, including acquisition prices of stablecoins used for payroll, holding periods, and specific identification of stablecoin lots used.
8. BSA / 31 CFR 1010(ff)(5).
9. Ibid.
10. Internal Revenue Service, “Frequently asked questions on virtual currency transactions” (August 22, 2024), https://www.irs.gov/individuals/international-taxpayers/frequently-asked-questions-on-virtual-currency-transactions.
11. See 29 C.F.R. §531.27(a).
12. IRS Notice 2014-21.
13. Cal. Lab. Code § 212(a)(1).
14. 9/7/16 N.Y. St. Reg. LAB-21-15-00009-A.
15. State of Washington, Department of Labor and Industries, Employment Standards, Administrative Policy, https://lni.wa.gov/workers-rights/_docs/esa2.pdf.
16. Texas Labor Code, Title 2. Protection of Laborers; Subchapter C. Wages; Chapter 61. Payment of Wages; Subchapter A. General Provisions, available at https://statutes.capitol.texas.gov/docs/LA/htm/LA.61.htm.

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