Hundreds of billions of dollars worth of Bitcoin assets—why does the ownership issue remain unresolved? The core problem lies in one question: the same asset is viewed very differently under the laws of different countries.

Taking the case of 127,000 Bitcoins (worth approximately $15 billion) as an example, there are at least four completely different legal interpretations regarding who should own it.

First, the origin of the asset itself carries a "multiple identity." Is Bitcoin property, currency, commodity, or investment asset? The United States, the European Union, Singapore, Japan, and Hong Kong each have their own definitions. The same digital asset might be recognized as private property in one country, considered a regulated financial instrument in another, or even face compliance barriers in a third. This fundamental ambiguity of identity directly leads to completely different ownership determinations.

Cross-border asset disputes are inherently complex, and the decentralized nature of Bitcoin makes the issue even more thorny. The collision of legal systems often results in cases stuck in a dilemma of "each side has its own reason."