May 14, 2025
I am writing in strong support of the proposed rule change to allow in-kind creation and redemption of shares in the iShares Bitcoin Trust (BlackRock), as outlined in SR-NASDAQ-2025-008. As a long-term Bitcoin holder, I believe this rule change would offer significant benefits to investors like me, particularly in terms of: Tax Efficiency: The ability to transfer Bitcoin in-kind into the ETF would allow me to defer capital gains taxes until I choose to sell the ETF shares. This is consistent with IRS-recognized in-kind contribution treatment and mirrors how many commodity-based ETFs already operate. Simplified Tax Reporting: Moving assets into the ETF through an in-kind transfer eliminates the need to calculate and report detailed capital gains and transaction histories on appreciated Bitcoin holdings. This would greatly reduce my annual tax reporting burden. Enhanced Asset Security: By transferring Bitcoin into a regulated, institutionally custodied ETF structure, I gain exposure to the asset without the direct custody risks associated with individual wallet management, exchange counterparty risk, or personal security practices. Market Integrity and Efficiency: The in-kind model avoids unnecessary market transactions (e.g., selling Bitcoin for cash), which can create slippage, increase spreads, and introduce potential manipulation. It supports a more efficient market structure and aligns with practices already common in traditional ETF mechanics. This proposal represents a meaningful advancement in how U.S. investors can securely and efficiently gain exposure to Bitcoin within a trusted regulatory framework. I urge the Commission to approve the rule change. Sincerely, Jeff Kleban