IRS Issues Revenue Ruling 2023-14 on Staking

On July 31, 2023, the IRS issued Revenue Ruling 2023-14, which sets forth the IRS’s position as to when certain staking “rewards” are taxable income. The Ruling analyzes a fact pattern where a cash method taxpayer “stakes 200 units of [token] M and validates a new block of transactions on the M blockchain, receiving 2 units of M as validation rewards.” The Ruling concludes that the taxpayer must include the “fair market value of the validation rewards received” in gross income during “the…
By: Fenwick & West LLP
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