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  1. Revenue Ruling 2023-14  provides that if a taxpayer stakes cryptocurrency native to a proof-of-stake blockchain and receives additional units of cryptocurrency as rewards when validation occurs, the fair market value of the rewards received is included in the taxpayer’s gross income in the taxable year in which the taxpayer gains dominion and control over the rewards.  The fair market value is determined as of the date and time the taxpayer gains dominion and control over the rewards.

    The revenue ruling clarifies that this is also the case if a taxpayer stakes cryptocurrency through a cryptocurrency exchange and the taxpayer receives additional units of cryptocurrency as rewards as a result of the validation.

    Revenue Ruling 2023-14 will be published in Internal Revenue Bulleting 2023-33 on Aug. 14, 2023

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