• videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Federal Tax Treatment of Cryptocurrency Mining and Staking Rewards

Rev. Proc. 2025-31 Safe Harbors, New Form 1099-DA, Identifying Taxable Events and Traps, Valuation

$347.00

This course is $0 with these passes:

CLE
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About the Course

Introduction

This CLE/CPE webinar will provide tax counsel, advisers, and market participants guidance on the current U.S. federal income tax treatment of cryptocurrency block rewards created or received from the "mining" or "staking" activities of the taxpayer that successfully validated transactions on the blockchain or other distributed ledger. The panel will discuss Rev. Rul. 2023-14, the Jarrett case, the “dominion and control” standard, reporting and new Form 1099-DA, valuation and determining basis of block rewards, and offer strategies for minimizing tax liability for cryptocurrency miners and stakers

Description

Cryptocurrency is a medium of exchange, created and stored electronically on the blockchain, using encryption techniques to verify the transfer of funds and an algorithm to control the creation of new units of cryptocurrency. Bitcoin and Ether are best known examples of cryptocurrency. The IRS requires taxpayers to report any transaction involving the "sale or exchange" of cryptocurrency, but IRS guidance also provides that mining and staking rewards are taxable upon receipt, i.e., before they are sold.

The "mining" of cryptocurrency is one way that transactions on the blockchain are verified (i.e., through a "proof of work" protocol), creating new tokens for the successful miner, which may subsequently be placed into public circulation. Typically, cryptocurrency miners receive newly minted virtual tokens and currencies for their mining activities, which the IRS appears to treat as a type of service, taxing the newly minted reward tokens upon receipt.

Alternatively, the "staking" of cryptocurrencies utilizes a "proof-of-stake" consensus mechanism, which is intended to solve the energy inefficiency of crypto mining, while offering comparable blockchain security (by ensuring that the public ledger remains decentralized). Participants (or validators) in a proof-of-stake blockchain lock a certain amount of their cryptocurrency in exchange for the right to validate transactions, and receive staking rewards in the form of new cryptocurrency in exchange for this. In 2023, the IRS issued Rev. Rul. 2023-14, providing that cash method taxpayers that receive staking rewards must include the fair market value of those rewards in income when they have “dominion and control” over the rewards, which generally is the time of creation.

Listen as our panel discusses the tax law underlying Rev. Rul. 2023-14, taxpayer challenges to the IRS position (e.g., the Jarrett case), valuation issues, reporting (including new Form 1099-DA), and the critical legal and factual issues that must be considered when determining the proper U.S. income tax treatment of crypto mining and stake reward transactions, including the recognition, timing, characterization, and reporting of mining and staking activities.

Presented By

Tom Geraghty
Shareholder
Vedder

Mr. Geraghty advises clients on tax aspects of complex domestic and cross-border transactions, long-term tax planning, tax position management and compliance, ensuring tax-efficient results that support their economic and business objectives. Clients ranging from small and mid-market private funds to startups and operating companies, and their executives and principals, rely on Mr. Geraghty for his forward-thinking strategies at all business stages. He advises on capital generation, fund and company formation, ongoing operations and tax-efficient outcomes at exit. Mr. Geraghty's experience spans joint ventures, mergers and acquisitions (including SPAC and up-C structures), securities offerings, equity investments, digital asset transactions (cryptocurrency, tokenized assets and smart contracts) and debt issuances.

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Megan L. Jones
Shareholder
Vedder

Ms. Jones is a highly skilled tax lawyer and a former investment banker who helps individuals, family offices and businesses navigate complex tax issues successfully. Combining a business-minded approach with cross-border experience and a results-driven focus, she structures tax-efficient transactions and tax plans while minimizing conflict. Ms. Jones's practice encompasses tax-efficient entity structuring, partnership and digital asset planning, and guidance through pre- and post-liquidity events. Startups, founders and established businesses rely on her for tax guidance on investments, cross-border mergers and acquisitions and going public. Ms. Jones helps clients manage complex holdings, private capital and multijurisdictional structures, advises on evolving tax regulations, and guides them from the startup phase through going public, domestic and international compliance, tax minimization and wealth preservation strategies.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, April 7, 2026

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

 


I. Overview of cryptocurrency and the mining and staking mechanisms

II. Overview of the tax treatment of cryptocurrency and digital assets

III. Tax treatment of mining of cryptocurrencies

IV. Tax treatment of staking of cryptocurrencies, including Rev. Rul. 2023-14 and other guidance to date

V. Valuation issues regarding mining and staking

VI. Liability for failing to report cryptocurrency transactions properly

VII. Key takeaways and pitfalls to avoid

VIII. Other interesting issues, including recent IRS guidance on staking rewards earned by exchange-traded funds, and the treatment of more complex staking structures.

The panel will review these and other key issues:

●     How does staking differ from mining, and how do they differ in terms of their U.S. income tax treatment?

●     What are the major tax pitfalls to avoid in advising clients who are involved in mining and/or staking activities?

●     How and when should mining and staking block rewards be valued?

●     What are the best practices in avoiding or managing an IRS examination involving mining and staking activities?