memorandum discusses certain federal income tax consequences applicable to The
Zerocoin Electric Coin Company ("ZECC") and its members with respect to the retention and
distribution of Zcash, as defined below ... Background
We understand the facts to be as follows. ZECC was formed on November 13, 2014,
with the purpose of developing an open-source, decentralized software protocol that produces ... rights to a virtual currency referred to as Zcash. The platform created by ZECC
allows owners of Zcash to engage in transactions with Zcash such that the details