Offshore BTC perp open interest sits in the tens of billions on Binance/Bybit/OKX — Kalshi is the first CFTC-regulated venue with a credible path to compete for it. The funding rate mechanism running through US rails will create persistent arbitrage against CME's quarterly futures, especially during volatility spikes when offshore funding goes parabolic. Institutional adoption hinges on Section 1256 treatment for perps — the IRS never updated guidance for funding-rate instruments and that ambiguity has kept most desks out.

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