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The character of staking rewards interest, rent, royalties, or a hidden partnership? Matthew E. Foreman and Michelle S. Kabel

By: Foreman, Matthew E.
Contributor(s): Kabel, Michelle S.
Material type: ArticleArticleSubject(s): CRIPTOMONEDA | MEDIOS DE PRUEBA | IMPUESTOS | ESTADOS UNIDOS In: Journal of Taxation of Investments v. 41, n. 1, Fall 2023, p. 57-65Summary: On July 31, 2023, the Internal Revenue Service (IRS) published Revenue Ruling 2023-14, regarding the tax treatment for cash method taxpayers that receive validation rewards in proof-of-stake transactions. The IRS confirmed its long-held position that validation rewards from a proof-of-stake consensus protocol are treated as gross income for cash-method taxpayers pursuant to Internal Revenue Code Section 61(a) when the taxpayer gains dominion and control over the validation rewards. This article considers what the character of that income should b
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Resumen.

On July 31, 2023, the Internal Revenue Service (IRS) published Revenue Ruling 2023-14, regarding the tax treatment for cash method taxpayers that receive validation rewards in proof-of-stake transactions. The IRS confirmed its long-held position that validation rewards from a proof-of-stake consensus protocol are treated as gross income for cash-method taxpayers pursuant to Internal Revenue Code Section 61(a) when the taxpayer gains dominion and control over the validation rewards. This article considers what the character of that income should b

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