Revenue Ruling 2019-24 addresses hard forks and airdrops, holding that new tokens received and controlled after a fork are ordinary income at fair market value, while a fork that produces no new tokens to the taxpayer creates no income.
The ruling introduced the dominion and control standard for receipt: income arises when the taxpayer can dispose of the new tokens, which may be later than the fork itself if an exchange delays support.
Why it matters: it is the authority behind income recognition for airdrops, and it is why the receipt date, not the announcement date, controls. See airdrop.
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