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Additional Guidance Provided on Receipt of Cryptocurrency, Rev. Rul. 2023-14

The IRS has released a revenue ruling providing additional guidance concerning receipt of cryptocurrency. If a cash-method 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 validation rewards received is included in the taxpayer’s gross income in the tax year in which the taxpayer gains dominion and control over the validation rewards. The same is true if a taxpayer stakes cryptocurrency native to a proof-of-stake blockchain through a cryptocurrency exchange and receives additional units of cryptocurrency as rewards as a result of the validation

Scenario in the Ruling

The revenue ruling presents a scenario in which transactions in a cryptocurrency that is convertible virtual currency are validated by a proof-of-stake consensus mechanism. A cash-method taxpayer validates a new block of transactions on the cryptocurrency blockchain, receiving two units of the cryptocurrency as validation rewards. Pursuant to the cryptocurrency protocol, during a brief period ending on Date 2, the taxpayer lacks the ability to sell, exchange, or otherwise dispose of any interest in the two units of cryptocurrency in any manner. On the following day (Date 3), the taxpayer has the ability to sell, exchange, or otherwise dispose of the two cryptocurrency units.

Analysis and Holding

Cryptocurrency that is convertible virtual currency is treated as property for Federal income tax purposes and general tax principles applicable to property transactions apply to transactions involving cryptocurrency. For example, a taxpayer who receives cryptocurrency as a payment for goods or services or who mines cryptocurrency must include the fair market value of the cryptocurrency in the taxpayer’s gross income in the tax year the taxpayer obtains dominion and control of the cryptocurrency.

In the scenario, two units of cryptocurrency represent the taxpayer’s reward for staking units and validating transactions on the blockchain. On Date 3, the taxpayer has an accession to wealth as the taxpayer gains dominion and control through the taxpayer’s ability, as of this date, to sell, exchange, or otherwise dispose of the two units of cryptocurrency received as validation rewards. Accordingly, the fair market value of the two units of cryptocurrency is included in taxpayer’s gross income for the tax year that includes Date 3.

IRS Highlights Home Energy Credits for Taxpayers, IR-2024-137

The IRS has advised taxpayers that making specific energy-efficient updates to their homes could qualify them for home energy credits. This guidance comes under the expanded provisions of […]

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IRS Highlights Home Energy Credits for Taxpayers, IR-2024-137

IRS Issues FAQs on Disaster Relief Related to Retirement Plans, FS-2024-19; IR-2024-132

The IRS issued frequently asked questions (FAQs) related to distributions from retirement plans and IRS for individuals impacted by federally declared disasters. These FAQs cover the ongoing disaster relief for certain distributions […]

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IRS Issues FAQs on Disaster Relief Related to Retirement Plans, FS-2024-19; IR-2024-132

2025 Inflation Adjustments for Health Savings Accounts Released, Rev. Proc. 2024-25

The IRS has released the 2025 inflation-adjusted amounts for health savings accounts under Code Sec. 223. For calendar year 2025, the annual limitation on deductions under Code Sec. 223(b)(2) for an […]

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2025 Inflation Adjustments for Health Savings Accounts Released, Rev. Proc. 2024-25

FL - Eligibility for tax credit scholarship program expanded

The eligibility for the Florida Tax Credit Scholarship Program is expanded for sales and use tax purposes. The scholarship program […]

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FL - Eligibility for tax credit scholarship program expanded

FL - IRC conformity tie-in date updated, disaster extension established

Florida updated the IRC conformity tie-in date for computing corporate income tax liability from January 1, 2023 to January 1, […]

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FL - IRC conformity tie-in date updated, disaster extension established

FL - Gas and Sulfur production tax rates for 2024-2025 announced

Florida has issued the severance tax rates for the production of gas and sulfur effective July 1, 2024, through June […]

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FL - Gas and Sulfur production tax rates for 2024-2025 announced

No Further Funding Cuts For IRS In FY24

Other than a planned repurposing of Inflation Reduction Act supplemental funding, the Internal Revenue Service saw no other cuts as the President signed off on the resolution […]

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No Further Funding Cuts For IRS In FY24

IRS Criminal Investigation Releases COVID Fraud Conviction Statistics, IR-2024-83

The IRS released statistics that showed 1,644 tax and money-laundering cases related to COVID fraud, totaling $9 billion investigated by the Criminal Investigation (CI). CI is the law enforcement […]

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IRS Criminal Investigation Releases COVID Fraud Conviction Statistics, IR-2024-83

IRS Updates FAQ on Commercial Clean Vehicle Credits (FS-2024-14; IR-2024-111)

The IRS updated frequently asked questions (FAQ) on New, Previously Owned and Qualified Commercial Clean Vehicle Credits. These FAQs provide guidance on how the Inflation Reduction […]

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IRS Updates FAQ on Commercial Clean Vehicle Credits (FS-2024-14; IR-2024-111)

2024 Foreign Housing Expense Amounts Released, Notice 2024-31

KPMG TaxNewsFlash – United States March 20, 2024 The IRS today released Notice 2024-31 [PDF 156 KB] providing the adjustments to the limitation on housing expenses, under […]

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2024 Foreign Housing Expense Amounts Released, Notice 2024-31