Dominion and control

Dominion and control is the standard the IRS uses to decide when you have received crypto as income: the moment you can transfer, sell, exchange, or otherwise dispose of it.

How it works

The IRS treats crypto as received, and therefore income, when you can transfer, sell, exchange, or otherwise dispose of it. Revenue Ruling 2019-24 applied the standard to airdrops and forks; Revenue Ruling 2023-14 applied it to staking rewards. Tokens locked in a protocol, credited to an exchange account that has frozen withdrawals, or not yet delivered to an address you control are generally not income until control exists.

Why it matters

The income date sets both the amount taxed and the basis of the tokens, and it is frequently later than the date a reward was announced or a fork occurred.

Related: staking rewards, airdrop.

Where this comes up in our work

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Definitions are general information, not legal advice, and may not reflect the most recent changes in law.