“It carries huge consequences for anyone engaging in mining or staking activities,” Dollar said. “If the IRS position is that it’s all taxable income at the time of creation, you’re currently taxed on any token rewards as they are earned before you dispose of them. Proponents of crypto take issue with that, even if you don’t buy the taxpayer-created property argument, a lot of these tokens are functioning in an inflationary environment where in staking there’s dilution when people create tokens, it’s more akin to a stock split – the units increase, the value technically decreases.”
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