BDO Insights
As a result of the Revenue Ruling, taxpayers would be well-advised to assess current and past staking rewards and consider at which point they obtained possession for tax purposes (dominion and control), and, therefore, when such rewards became taxable.
Interesting:
The release of the ruling comes as litigation regarding staking rewards continues to play out in Jarrett v. United States, No. 22-6023 (6th Cir. 2023). The taxpayer’s argument in Jarrett is that staking rewards are akin to self-created property (such as mineral extraction from a mine) and therefore should not be taxed until the ultimate disposition of the property. The case recently went through oral arguments in the Sixth Circuit.
