Staking Rewards: When Is Crypto Income Taxable? (LA Tech Week Debate)

At LA Tech Week 2025 (October 13-19), one of the most heated debates was about staking reward taxation. Tax professionals, crypto developers, and protocol founders had completely different views on when staking rewards should be recognized as taxable income.

This is CRITICAL for accountants because the IRS position is unclear, clients are confused, and the tax liability can be MASSIVE if you get it wrong.

What Is Crypto Staking?

For those less familiar with the mechanics:

Proof-of-Stake (PoS) blockchains (Ethereum, Cardano, Solana, etc.) reward participants for “staking” their tokens to help secure the network.

How it works:

  1. You lock up your tokens (e.g., 32 ETH for Ethereum)
  2. Your tokens participate in network validation
  3. You receive staking rewards (additional tokens) over time
  4. Rewards typically 4-8% APY (annual percentage yield)

Example:

  • Stake 32 ETH (worth $96,000 at $3,000/ETH)
  • Earn 5% APY = 1.6 ETH per year
  • Monthly rewards: ~0.133 ETH (~$400/month)

The tax question: WHEN do you recognize $400/month income?

  • Upon receipt (even if locked)?
  • When you can withdraw?
  • When you actually sell?

The IRS Position (Sort Of)

IRS Notice 2014-21: Virtual currency (including crypto) is property.

General tax principle: Income from property is taxable upon receipt.

IRS Chief Counsel Advice (CCA) 202124008 (June 2021):
Discussed whether newly created cryptocurrency (through mining or similar) is taxable upon receipt or upon sale.

Implication: IRS likely treats staking rewards as income upon receipt.

BUT: No official IRS guidance specifically addressing staking rewards. We’re applying general principles.

The Jarrett v. United States Case (2023)

This is THE case everyone at LA Tech Week was discussing.

Background:

  • Joshua Jarrett staked Tezos (XTZ) tokens
  • Received staking rewards
  • Filed tax return treating rewards as income upon receipt
  • Later filed amended return seeking refund, arguing rewards shouldn’t be taxed until sold
  • Sued IRS for refund

Jarrett’s argument:
Staking rewards are “newly created property” (like a baker making bread from flour). Under IRC Section 61, creation of property isn’t taxable until you sell it.

IRS argument:
Staking rewards are compensation for services (validating transactions), therefore taxable as ordinary income upon receipt.

District Court ruling (May 2023):
Sided with Jarrett - ruled rewards are “newly created property” and not taxable until sold.

IRS response:
Did NOT issue a refund. Instead, government is appealing the case.

Current status (October 2025):
Case is on appeal. We’re waiting for Circuit Court ruling.

What this means for accountants:

  • Conflicting positions (District Court vs. IRS)
  • No final guidance
  • Clients caught in the middle
  • We have to advise despite uncertainty

The Four Main Positions

At LA Tech Week, I heard four different tax positions:

Position 1: Conservative (IRS Position)

Income upon receipt, even if locked/illiquid

Rationale:

  • Follows general tax principles (income from property taxable upon receipt)
  • Aligns with IRS Chief Counsel Advice
  • Staking rewards = compensation for network validation services
  • Similar to stock dividends (taxable when declared, even if can’t sell immediately)

Tax treatment:

  • Ordinary income at fair market value on receipt date
  • Report on Schedule 1 (Line 8z - Other income)
  • Creates cost basis for future sale

Example:

  • Receive 0.133 ETH in October 2025
  • ETH = $3,150 on receipt date
  • Ordinary income: $419 (0.133 × $3,150)
  • Cost basis of received ETH: $419
  • Later sell ETH for $3,500: Capital gain of $47 (0.133 × [$3,500 - $3,150])

Pros:

  • Low audit risk
  • Aligns with IRS position
  • Defensible

Cons:

  • Pay tax on illiquid assets
  • Need cash reserves to pay tax
  • Higher current tax burden

Position 2: Moderate (Receipt When Accessible)

Income when you have unfettered access

Rationale:

  • Constructive receipt doctrine: Income taxable when you have unfettered access
  • If tokens are locked (can’t withdraw), you don’t have constructive receipt
  • Once unlock period ends, THEN you have income
  • Aligns with employment law (restricted stock not taxable until vested)

Tax treatment:

  • No income if rewards locked
  • Income upon unlock/accessibility
  • Report as ordinary income when accessible

Example:

  • Receive 0.133 ETH in staking rewards (October 2025)
  • ETH locked for 6 months (can’t withdraw until April 2026)
  • No income in 2025
  • April 2026: ETH unlocks at $3,400/ETH
  • 2026 income: $452 (0.133 × $3,400)

Pros:

  • Matches cash flow (only taxed when you can access)
  • Constructive receipt doctrine support
  • More “fair” for locked tokens

Cons:

  • IRS may disagree
  • Tracking unlock dates is burdensome
  • Higher audit risk than Position 1

Position 3: Aggressive (Jarrett Position)

No income until sold

Rationale:

  • Staking rewards are “newly created property”
  • Creation of property isn’t taxable event
  • Only taxable upon disposition (sale)
  • Supported by Jarrett District Court ruling

Tax treatment:

  • No income when received
  • All gains reported as capital gains when sold
  • Cost basis = $0 (nothing paid for rewards)

Example:

  • Receive 0.133 ETH in October 2025
  • No income reported in 2025
  • Sell in December 2025 for $3,200
  • Capital gain: $426 (0.133 × $3,200 - $0 basis)

Pros:

  • Defer all tax until sale
  • All income taxed as capital gains (lower rates)
  • Supported by one court ruling

Cons:

  • IRS is appealing (may be overturned)
  • High audit risk
  • Penalties if IRS prevails
  • All gain taxed as short-term capital gains (equivalent to ordinary income rates if held < 1 year)

Position 4: Hybrid (Elective Method)

Report conservatively, but build cash reserves expecting future law change

Rationale:

  • Report as income upon receipt (Position 1) to be safe
  • But expect Jarrett ruling may prevail
  • If law changes, file amended returns for refunds
  • Avoid underpayment penalties while preserving future flexibility

Tax treatment:

  • Current: Report as income upon receipt
  • Future: If Jarrett prevails, amend prior returns and claim refunds

Pros:

  • No audit risk
  • No underpayment penalties
  • Can recover taxes if law changes

Cons:

  • Pay maximum tax upfront
  • Refund process takes years
  • Opportunity cost of taxes paid early

The Locked Staking Problem

This is where it gets REALLY controversial.

Many staking protocols lock tokens for months:

  • Ethereum: Staked ETH was locked until “Shapella” upgrade (April 2023)
  • Cardano: Staking rewards accessible but original stake locked for 5 days
  • Polkadot: 28-day unbonding period
  • Some liquid staking protocols: 6-12 month lock-ups

The tax problem:
If you receive $10,000 in staking rewards but can’t sell for 12 months, where do you get cash to pay $4,000 in taxes (40% rate)?

Real client scenario from LA Tech Week discussion:

Client: Institutional investor

  • Staked 1,000 ETH (when ETH = $2,000) = $2M position
  • 5% APY = 50 ETH/year in rewards
  • Rewards worth $100K/year
  • Tax at 40% = $40K/year tax bill
  • Problem: ETH was locked (before Shapella upgrade), couldn’t sell to pay taxes

Options client considered:

  1. Sell other assets to pay tax (but didn’t want to liquidate other holdings)
  2. Borrow against ETH (but DeFi rates were 8-12%, expensive)
  3. Pay quarterly estimated taxes from operating cash (reduced business liquidity)
  4. Take aggressive position (don’t report until liquid) - RISKY

What client did: Paid taxes from operating cash, but resented “paying tax on phantom income.”

The Liquidity Timing Mismatch

Even when rewards are “accessible,” they may not be liquid (sellable).

Example - Staking obscure token:

  • Stake 100,000 tokens of small-cap altcoin
  • Receive 5,000 tokens/year in rewards
  • 5,000 tokens × $2/token = $10,000 income
  • Tax due: $4,000 (40%)

Problem:

  • Token has thin liquidity (only $500/day trading volume)
  • Selling 5,000 tokens would crash price
  • Can’t realistically sell to pay taxes
  • Must use other funds to pay $4,000 tax

This is common for:

  • Small-cap altcoins
  • New protocol tokens
  • Governance tokens with low liquidity

Different Staking Models - Different Tax Treatment?

At LA Tech Week, developers pointed out there are MANY different staking models:

1. Native Protocol Staking (Direct Validator)

Example: Running Ethereum validator node (32 ETH minimum)

Characteristics:

  • You directly validate transactions
  • Receive block rewards + transaction fees
  • Active participation required

Tax argument FOR ordinary income:

  • You’re providing services (validation)
  • Compensation for work performed
  • Similar to mining income (clearly ordinary income)

2. Delegated Staking

Example: Delegate to Coinbase or other staking provider

Characteristics:

  • You delegate tokens to professional validator
  • Validator does the work
  • You receive portion of rewards (minus validator fee)

Tax argument FOR ordinary income:

  • Similar to dividend income or interest
  • Passive return on investment
  • Report as “other income”

3. Liquid Staking Derivatives

Example: Lido (stETH), Rocket Pool (rETH)

Characteristics:

  • Deposit ETH, receive derivative token (stETH)
  • Derivative token appreciates as staking rewards accrue
  • Can trade derivative token immediately (liquid)

Tax question:

  • Is this a taxable exchange? (ETH → stETH)
  • When are rewards recognized? (Continuously as stETH appreciates? Or upon redemption?)

IRS hasn’t addressed this AT ALL.

Conservative approach:

  • Treat ETH → stETH exchange as taxable event (like crypto-to-crypto swap)
  • Track cost basis of stETH
  • Recognize gain/loss when redeem stETH for ETH

Aggressive approach:

  • Treat stETH as “receipt” of ETH (not taxable exchange)
  • No income until redeem stETH
  • Gain/loss calculated at redemption

4. DeFi Yield Farming Disguised as “Staking”

Example: Many DeFi protocols call liquidity provision “staking”

Characteristics:

  • Deposit tokens into liquidity pool
  • Receive “staking rewards” (actually LP rewards)
  • Much higher yields (20-300% APY - unsustainable)

Tax treatment:

  • This is NOT staking (it’s yield farming)
  • Rewards are ordinary income upon receipt (clear IRS position)
  • See our earlier DeFi discussion

How to Track Staking Rewards in Beancount

Regardless of which tax position you take, you need to track:

  • Amount received
  • Date received
  • FMV at receipt
  • Cost basis
  • Holding period

Conservative approach (Position 1 - Income upon receipt):

2025-10-15 * "Ethereum Staking Reward" #staking-income
  reward_amount_eth: 0.133
  eth_usd_rate: 3150.00
  reward_value_usd: 419.00
  tax_treatment: "ordinary_income"
  source: "Coinbase Staking"
  Income:Staking:ETH              -419.00 USD
  Assets:Crypto:ETH:Staked       0.133 ETH @ 3150.00 USD

When later sold:

2026-03-20 * "Sell Staked ETH" #staking-sale
  amount_sold_eth: 0.133
  cost_basis_usd: 419.00  ; From staking reward recognition
  sale_price_usd: 3500.00
  proceeds: 465.50
  capital_gain: 46.50
  holding_period: "long_term"  ; Held > 1 year from receipt
  Assets:Crypto:ETH:Staked       -0.133 ETH @ 3150.00 USD
  Assets:Checking                465.50 USD
  Income:CapitalGains:LongTerm   -46.50 USD

Aggressive approach (Position 3 - No income until sold):

2025-10-15 * "Ethereum Staking Reward Received" #staking-receipt
  reward_amount_eth: 0.133
  cost_basis: 0.00  ; No basis if not recognized as income
  tax_treatment: "deferred_until_sale"
  note: "Following Jarrett case theory"
  Assets:Crypto:ETH:Staked       0.133 ETH @ 0.00 USD

2026-03-20 * "Sell Staked ETH - Recognize All Gain" #staking-sale-aggressive
  amount_sold_eth: 0.133
  cost_basis: 0.00
  sale_price: 3500.00
  total_gain: 465.50  ; All proceeds = gain (zero basis)
  holding_period: "short_term"  ; From receipt to sale < 1 year
  Assets:Crypto:ETH:Staked       -0.133 ETH @ 0.00 USD
  Assets:Checking                465.50 USD
  Income:CapitalGains:ShortTerm  -465.50 USD

The Quarterly Estimated Tax Challenge

If you take Position 1 (conservative), you must pay estimated taxes QUARTERLY on illiquid staking rewards.

Example calculation:

Q4 2025 staking rewards:

  • Received 0.4 ETH in rewards
  • Average ETH price: $3,200
  • Total income: $1,280

Estimated tax due (by January 15, 2026):

  • Federal tax (32% bracket): $410
  • Self-employment tax (15.3%): $196
  • State tax (5%): $64
  • Total: $670

Problem: Client must pay $670 in cash for $1,280 in ETH rewards they may not have sold.

My Recommendation Framework

After LA Tech Week discussions, here’s my advice to clients:

For Small Stakes (<$10K/year rewards): Position 1 (Conservative)

  • Report income upon receipt
  • Pay estimated taxes quarterly
  • Low audit risk, sleep well at night

For Medium Stakes ($10K-$100K/year rewards): Position 2 (Moderate)

  • If rewards clearly locked/inaccessible: Defer until accessible
  • Document lock-up terms extensively
  • Recognize income when withdraw-eligible
  • Reasonable middle ground

For Large Stakes (>$100K/year rewards): Position 1 + Tax Planning

  • Report conservatively (income upon receipt)
  • BUT implement tax mitigation:
    • Sell portion of rewards immediately to cover taxes
    • Use DeFi borrowing to cover tax payments (if rates favorable)
    • Charitable donations of appreciated tokens (if charitably inclined)
    • Consider staking through IRA (if qualified custodian available)

NEVER Recommend: Position 3 (Jarrett) for most clients

  • Too aggressive given IRS is appealing
  • High penalty risk if overturned
  • Only for sophisticated taxpayers willing to fight IRS in Tax Court

Questions for the Community

  1. What position are you taking with your clients? Conservative (1), Moderate (2), or Aggressive (3)?

  2. For those taking Position 1: How are clients reacting to paying tax on illiquid staking rewards?

  3. For Beancount users: How are you tracking the “income recognized” vs. “cash received” timing difference?

  4. Has anyone had clients audited on staking rewards? What did IRS focus on?

  5. What happens when Jarrett case concludes? If IRS loses appeal, do we amend all prior returns?

The Bottom Line

Staking reward taxation is:

  • Legally uncertain (Jarrett case pending)
  • Administratively burdensome (tracking each reward)
  • Cash-flow challenging (taxed on illiquid income)
  • Evolving rapidly (expect IRS guidance eventually)

My conservative recommendation: Report as income upon receipt UNLESS rewards are clearly locked and inaccessible for extended period.

Document everything: Whatever position you take, document your reasoning thoroughly. IRS will ask questions.

From LA Tech Week: This was the #1 most debated crypto tax issue. Everyone agrees we need clear IRS guidance. Until then, we’re navigating gray areas.

Fred Wilson, CFA
Financial Planning & Analysis


P.S. - I’m tracking the Jarrett case closely. When Circuit Court rules, I’ll post an update. Also working on a “Staking Rewards Tax Position Memo” template for client files - will share if there’s interest.

Key Sources:

  • LA Tech Week 2025 (October 13-19)
  • Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn. May 26, 2023)
  • IRS Notice 2014-21
  • IRS Chief Counsel Advice 202124008
  • Rev. Rul. 2019-24 (crypto fork taxation)

Fred, this is THE most important crypto tax discussion we’ve had. Staking reward taxation keeps me up at night because I’m advising clients without clear IRS guidance, and the stakes (pun intended) are huge.

Let me add the IRS enforcement and audit defense perspective, because this is where rubber meets road.

What IRS Examiners Are Looking For

I’ve had 3 clients audited on crypto returns in past 2 years. Here’s what IRS is focusing on:

Audit Trigger #1: Unreported Staking Income

What happened:

  • Client received Form 1099-MISC from Coinbase showing $12,000 in staking rewards
  • Client didn’t report it (took aggressive “not taxable until sold” position)
  • IRS computer matching flagged the discrepancy
  • Automatic CP2000 notice issued

Result:

  • IRS asserted $12,000 additional income
  • Tax due: $4,320 (36% marginal rate)
  • Accuracy-related penalty (20%): $864
  • Interest: $347
  • Total: $5,531

Lesson: If exchange issues 1099, you MUST report it or explain why not.

Audit Trigger #2: Inconsistent Reporting Year-over-Year

What happened:

  • Client reported staking rewards as income upon receipt in 2023
  • Switched to “not taxable until sold” position in 2024 (after reading about Jarrett case)
  • IRS flagged inconsistent treatment

IRS position:
“You can’t change accounting methods without filing Form 3115 (Application for Change in Accounting Method). Your 2024 return used wrong method.”

Result:

  • IRS disallowed the method change
  • Required to continue reporting as income upon receipt
  • No penalties (since client had legitimate disagreement), but owed back taxes

Lesson: Can’t switch tax positions year-to-year without formal accounting method change.

Audit Trigger #3: Large Staking Rewards with No Estimated Tax Payments

What happened:

  • Client reported $85,000 in staking income on 2024 return
  • Zero estimated tax payments made during 2024
  • IRS flagged for underpayment penalty

Calculation:

  • Tax due: $30,600
  • Required estimated payments: $27,540 (90% of current year tax)
  • Actual paid: $0
  • Underpayment penalty: $2,156

Lesson: Staking income requires quarterly estimated tax payments.

The Form 1099-MISC Problem (Starting 2025)

Fred mentioned Form 1099-DA (gross proceeds), but staking rewards are actually reported on Form 1099-MISC.

IRC Section 6045 requires brokers to report:

  • Payments of $600 or more
  • Made in the course of business

Centralized exchanges (Coinbase, Kraken, Gemini) issue Form 1099-MISC for staking rewards starting 2025.

What’s reported:

  • Box 3: “Other Income”
  • Amount: USD value of all staking rewards paid during year
  • Reported to both taxpayer and IRS

The matching problem:

Scenario:

  • Coinbase reports $15,000 in staking rewards on your Form 1099-MISC
  • You report $0 (taking Jarrett position - not taxable until sold)
  • IRS computer WILL flag this mismatch

What happens next:

  • CP2000 notice proposing $15,000 additional income
  • You must respond within 30 days explaining your position
  • Burden of proof is on YOU to show why 1099 is wrong

My recommendation:
If you’re taking aggressive position (Jarrett), you MUST:

  1. Attach statement to tax return explaining position
  2. Cite Jarrett case (No. 3:21-cv-00419)
  3. Disclose under IRC § 6662(d)(2)(B) to avoid accuracy penalty
  4. Prepare for IRS inquiry

The Constructive Receipt Doctrine Deep Dive

Fred mentioned Position 2 (income when accessible). Let me explain the tax law:

IRC Treas. Reg. § 1.451-2: Constructive Receipt

Income is constructively received when:

  1. Amount is credited to your account
  2. Set apart for you
  3. Made available to you
  4. You can draw upon it at any time without substantial restrictions

Key phrase: “Substantial restrictions”

Examples of substantial restrictions (NO constructive receipt):

  • Funds held in escrow (can’t access)
  • Certificate of deposit before maturity (penalty for early withdrawal)
  • Restricted stock (can’t sell until vesting)

Question: Are locked staking rewards “substantially restricted”?

Arguments FOR substantial restriction (defer income):

  • Can’t withdraw (technical impossibility)
  • Network protocol prevents access
  • No way to convert to cash
  • Similar to unvested restricted stock

Arguments AGAINST (income upon receipt):

  • You have ownership rights immediately
  • Restriction is temporary (will unlock eventually)
  • You chose to lock them (voluntary restriction)
  • Different from unvested stock (employer controls vesting, you control nothing)

IRS will likely argue:
Voluntary restrictions don’t qualify. You CHOSE to stake, knowing the lock-up terms.

My conservative position:
Assume IRS view prevails. Report as income unless restriction is (1) involuntary and (2) long-term (>1 year).

The Jarrett Case: What Happens Next?

Everyone’s watching this case. Let me explain the procedural posture:

District Court (May 2023): Ruled for Jarrett (taxpayer wins)

IRS response: Did NOT acquiesce (accept the ruling)

Current status: Government appealed to 6th Circuit Court of Appeals

Possible outcomes:

Outcome 1: 6th Circuit Affirms (Jarrett wins again)

  • Staking rewards NOT taxable until sold
  • BUT: Only binding in 6th Circuit (TN, KY, OH, MI)
  • Other circuits may rule differently
  • IRS may appeal to Supreme Court

Impact on taxpayers:

  • If you live in 6th Circuit: Strong argument for deferral
  • If you live elsewhere: Not binding precedent
  • IRS may continue to assert tax due in audits

Outcome 2: 6th Circuit Reverses (IRS wins)

  • Staking rewards taxable upon receipt
  • Becomes precedent for 6th Circuit
  • IRS will use to audit taxpayers nationwide

Impact on taxpayers:

  • Everyone who took Jarrett position owes back taxes
  • Underpayment penalties likely
  • Accuracy-related penalties possible (20%)
  • Interest accrues from original due date

Outcome 3: Narrow Ruling (Specific to Tezos Facts)

  • Court rules on narrow grounds specific to Tezos protocol
  • Doesn’t establish broad precedent
  • Other staking protocols may be treated differently

Impact: Continued uncertainty, case-by-case analysis required

Timeline:

  • Oral arguments: Expected early 2026
  • Decision: Mid to late 2026
  • If appealed to Supreme Court: 2027-2028

We won’t have certainty for 1-2 more years.

The Amended Return Risk

Fred asked: “If Jarrett prevails, do we amend prior returns?”

YES, but there are timing limits:

IRC § 6511: Statute of Limitations for Refunds

  • Must file amended return within 3 years of original filing date
  • Or within 2 years of paying the tax (whichever is later)

Scenario:

Client filed 2024 return (April 15, 2025):

  • Reported $20,000 staking income (conservative position)
  • Paid $7,200 in tax

Jarrett appeal concludes (June 2026):

  • IRS loses, confirms staking rewards not taxable until sold
  • Client wants refund

Action:

  • File Form 1040-X (Amended Return) by April 15, 2028 (3 years from original filing)
  • Claim refund of $7,200
  • Cite Jarrett case and final regulations

The risk:

  • IRS may take months/years to process refund
  • Opportunity cost of taxes paid early
  • No interest paid on refund (usually)

My recommendation:
If taking conservative position, document client’s preference and confirm they understand may not get refund if law changes.

Penalty Protection: IRC § 6662 Disclosure

If you’re taking aggressive position (Jarrett), you MUST disclose to avoid penalties.

IRC § 6662: Accuracy-Related Penalty (20%)

Applies if:

  • Substantial understatement of income
  • Understatement exceeds greater of $5,000 or 10% of correct tax

Exception: No penalty if you have “reasonable cause” and “acted in good faith.”

How to establish reasonable cause:

Method 1: Attach Disclosure Statement to Return

File Form 8275 (Disclosure Statement) with tax return:

Sample disclosure:

"DISCLOSURE PURSUANT TO IRC § 6662(d)(2)(B)

Position Taken: Cryptocurrency staking rewards not taxable until sold.

Authority: Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn. May 26, 2023)

Facts: Taxpayer received 50 ETH in staking rewards during 2025. Taxpayer treated these rewards as non-taxable newly created property, recognizing income only upon sale pursuant to District Court ruling in Jarrett.

Amount: $150,000 (50 ETH × $3,000 average price)

Taxpayer acknowledges IRS disagrees with this position. Taxpayer relies on District Court precedent and believes position has reasonable basis in law."

Effect:

  • Penalty protection if position has “reasonable basis” (>20% chance of success)
  • IRS must still determine whether tax is owed
  • But no 20% penalty if IRS prevails

Method 2: Opinion Letter from Tax Professional

Obtain written opinion from CPA/EA/attorney:

Opinion should state:

  1. Facts of client’s situation
  2. Tax position taken
  3. Legal authorities supporting position (Jarrett case, constructive receipt doctrine, etc.)
  4. Analysis of strengths and weaknesses
  5. Conclusion that position has “substantial authority” or “reasonable basis”

Cost: $2,000-$5,000 for opinion letter

Benefit: Strong penalty protection if IRS challenges position

Estimated Tax Calculation for Staking Income

Fred mentioned quarterly estimated taxes. Let me show exact calculation:

Client staking 100 ETH, earning 5% APY:

Quarterly staking rewards:

  • Q1: 1.25 ETH × $2,800 = $3,500
  • Q2: 1.25 ETH × $3,100 = $3,875
  • Q3: 1.25 ETH × $3,300 = $4,125
  • Q4: 1.25 ETH × $3,000 = $3,750
  • Total: $15,250

Tax calculation (single filer, $150K other income):

  • Marginal federal rate: 24%
  • Net investment income tax: 3.8%
  • State tax (CA): 9.3%
  • Total rate: 37.1%

Tax on staking income: $5,658

Quarterly estimated payments (due 4/15, 6/15, 9/15, 1/15):

  • Q1 (by 4/15/2025): $1,295
  • Q2 (by 6/15/2025): $1,438
  • Q3 (by 9/15/2025): $1,531
  • Q4 (by 1/15/2026): $1,394

Underpayment penalty if not paid:

  • IRS charges interest on underpayments
  • Current rate: ~8% annually
  • Compounded quarterly
  • On $5,658 underpayment for full year: ~$226 penalty

Safe harbor:
Pay 100% of prior year tax (110% if AGI > $150K) to avoid penalty.

State Tax Complications

Don’t forget: State tax treatment may differ from federal.

States with specific crypto guidance:

California

  • Follows federal treatment generally
  • Staking rewards = income upon receipt
  • Reported on California Schedule CA

New York

  • Follows federal treatment
  • Staking rewards = ordinary income
  • Subject to NY state tax (up to 10.9%)

Wyoming

  • Crypto-friendly legislation
  • But still taxes staking rewards as income
  • No special exemptions

Texas, Florida, Nevada, Washington

  • No state income tax
  • Staking rewards federally taxable but no state tax component

Multi-state issues:

  • If you move mid-year, apportion staking income by state
  • Track which quarters you were resident of which state
  • File part-year returns for each state

Record-Keeping Requirements

IRS will want to see:

Required documentation for staking rewards:

  1. Transaction records:

    • Date and time of each reward
    • Amount received (in crypto)
    • Fair market value at time of receipt (USD)
    • Source (which validator, which exchange)
  2. Lock-up terms (if claiming deferral):

    • Protocol documentation showing lock period
    • Dates when rewards become accessible
    • Evidence you couldn’t withdraw
  3. Fair market value determination:

    • Which exchange price used?
    • Screenshot of price on receipt date
    • If multiple exchanges, which one and why?
  4. Estimated tax payment records:

    • Form 1040-ES vouchers
    • Proof of payment (cancelled checks, bank records)
    • Quarterly calculations
  5. Form 1099-MISC (when issued):

    • Keep copy of all 1099s received
    • Reconcile to your records
    • Explain any differences

How long to keep:

  • General rule: 3 years from filing date
  • If substantial understatement (>25%): 6 years
  • If fraud alleged: Indefinite
  • My recommendation: Keep crypto records 7 years minimum

My Client Advisory Template

When client asks about staking, I provide written advisory:

Sample language:

"STAKING REWARDS TAX ADVISORY

Client: [Name]
Date: October 20, 2025
Prepared by: Tina Chen, EA

FACTS:
You are considering staking [amount] [token]. Estimated annual rewards: [amount] ([value] at current prices).

IRS POSITION:
IRS likely treats staking rewards as ordinary income upon receipt, based on general principles. No explicit guidance issued yet.

LEGAL UNCERTAINTY:
Jarrett v. United States case pending appeal. Outcome uncertain. Expected resolution 2026-2027.

TAX POSITIONS AVAILABLE:

Position 1 (Conservative): Report as ordinary income upon receipt

  • Risk level: Low
  • Audit risk: Low
  • Penalty risk: None
  • Cash flow impact: Highest (pay tax on illiquid income)

Position 2 (Moderate): Report as income when accessible (if locked)

  • Risk level: Medium
  • Audit risk: Medium
  • Penalty risk: Low (if well-documented)
  • Cash flow impact: Medium (deferred but still on illiquid income)

Position 3 (Aggressive): Report as income only upon sale (Jarrett position)

  • Risk level: High
  • Audit risk: High
  • Penalty risk: Medium-High (if Jarrett reversed on appeal)
  • Cash flow impact: Lowest (only taxed when sell)

RECOMMENDATION:
[Insert recommendation based on client risk tolerance, amount at stake, etc.]

ESTIMATED TAX IMPACT:
[Insert calculations]

QUARTERLY ESTIMATED PAYMENTS REQUIRED:
Q1: $[amount] by 4/15
Q2: $[amount] by 6/15
Q3: $[amount] by 9/15
Q4: $[amount] by 1/15

CLIENT ACKNOWLEDGMENT:
I understand the uncertainty and risks. I choose to take Position [1/2/3] and acknowledge this may result in [penalties/audit/additional tax] if IRS disagrees.

Client Signature: _________________ Date: _________"

This protects both me and client.

Questions for Fred and Community

  1. Fred: For your institutional client who paid taxes from operating cash, did they build this into their staking ROI model? How much did tax drag reduce effective yield?

  2. For everyone: Has anyone successfully used the “substantial restrictions” argument to defer staking income? Did IRS accept it?

  3. For CPAs: Are you charging extra for the uncertainty risk? I’m adding 25% surcharge for staking returns due to research time and potential IRS defense work.

  4. Has anyone filed Form 8275 disclosure for staking positions? Did it attract IRS scrutiny or provide penalty protection?

My Bottom Line

Staking reward taxation is legally uncertain and administratively burdensome.

My standard advice:

  • Default to conservative (income upon receipt)
  • Consider moderate approach if clear lock-up > 6 months
  • Avoid aggressive Jarrett position unless client sophisticated and willing to fight IRS
  • ALWAYS document position in writing
  • Pay quarterly estimated taxes
  • Prepare for IRS guidance to change everything

The key: Whatever position you take, DOCUMENT thoroughly and disclose to IRS if aggressive.

When Jarrett case concludes, I’ll post an update. Until then, we’re navigating uncertain waters.

Tina Chen, EA
Tax Specialist


P.S. - I’m drafting a “Staking Tax Position Advisory Template” and “Form 8275 Sample Disclosure” for staking rewards. If there’s interest, I’ll share with community.

Fred and Tina - brilliant discussion. I need to add the CPA practice management angle because staking creates unique client relationship challenges that go beyond just “what’s the right tax answer.”

The Client Expectation Problem

Here’s the conversation I have EVERY tax season:

Client: “I staked my crypto and earned $50,000 in rewards!”
Me: “Congratulations. That’s $20,000 in taxes due.”
Client: “WHAT?! But I can’t sell the tokens!”
Me: “IRS taxes you on receipt, not when you can sell.”
Client: “That’s insane! I don’t have $20,000 cash!”
Me: “I understand, but that’s the conservative tax position.”
Client: “Well I saw online that Jarrett case says I don’t have to pay tax until I sell!”
Me: “That case is on appeal and IRS disagrees. Do you want to fight IRS in Tax Court?”
Client: “…”

This conversation happens constantly.

The “Crypto YouTube Lawyer” Problem

Clients watch YouTube videos from crypto influencers saying “staking rewards aren’t taxable!” and come to me expecting me to agree.

What clients heard:

  • “Jarrett case proves staking isn’t taxable!”
  • “IRS has no authority to tax staking!”
  • “Just don’t report it, they can’t catch you!”
  • “It’s newly created property, not income!”

What clients don’t understand:

  • Jarrett case is ONE district court ruling (not final)
  • IRS is appealing (government disagrees)
  • Only applies in 6th Circuit (even if affirmed)
  • Taking aggressive position = audit risk + penalties

My new policy:
When client mentions “I saw on YouTube that…”, I stop them and say:

“YouTube is entertainment, not legal advice. I’m a licensed CPA responsible for your tax return. If IRS audits you, YouTube personality won’t represent you - I will. We’re taking the conservative position that protects you.”

Some clients fire me for this. That’s fine. I’d rather lose a client than defend an indefensible tax return.

The Fee Negotiation Problem

Staking returns are MORE complex than normal crypto returns.

Why staking adds complexity:

  1. Must track EVERY reward distribution (could be daily/weekly)
  2. Must determine FMV at time of each receipt
  3. Must calculate estimated tax payments quarterly
  4. Must document lock-up terms (if claiming deferral)
  5. Must prepare disclosure statements (if taking aggressive position)
  6. Must be ready to defend in audit

Time required:

  • Simple staking (1 token, quarterly distribution): +3 hours
  • Complex staking (5 tokens, daily rewards): +15 hours
  • Institutional staking (large amounts, multiple protocols): +40 hours

My pricing:

Staking supplement to base return fee:

  • Simple (1-2 tokens, < 50 rewards/year): $750
  • Moderate (3-5 tokens, 50-200 rewards): $1,500
  • Complex (5+ tokens, 200+ rewards): $3,000+
  • Institutional (multi-million dollar stakes): $10,000+

Client pushback:

“Why so expensive? It’s just passive income like dividends!”

My response:

“Dividends have clear tax treatment (qualified vs ordinary) and broker provides Form 1099-DIV with all information. Staking has unclear tax treatment, requires us to research legal issues, track every distribution manually, potentially prepare disclosure statements, and defend in audit. This isn’t passive - it’s complex legal analysis.”

If client won’t pay: I decline the engagement. Not worth the professional liability risk.

The Professional Liability Risk

This is what keeps me up at night.

Scenario 1: Client takes aggressive position, I sign return

  • Client insists on using Jarrett position (no tax until sold)
  • I prepare return with that position and sign as preparer
  • IRS audits and assesses $30,000 additional tax + penalties
  • Client sues me for malpractice: “You should’ve advised me not to take that position”

My liability exposure:

  • $30,000 (client’s tax bill)
  • $6,000 (penalties)
  • $2,000 (interest)
  • $10,000 (client’s attorney fees suing me)
  • Total: $48,000 risk

Scenario 2: Client takes conservative position, Jarrett wins on appeal

  • I advise conservative position (income upon receipt)
  • Client pays $30,000 in taxes over 3 years
  • Jarrett case concludes 2026 - IRS loses
  • Final regulations say staking not taxable until sold
  • Client could’ve saved $30,000
  • Client sues me: “You gave bad advice, I overpaid taxes”

My liability exposure:

  • $30,000 (client’s overpaid taxes)
  • $5,000 (client’s attorney fees)
  • Total: $35,000 risk

I CAN’T WIN EITHER WAY.

My solution:
Written advisory (like Tina’s template) explaining all positions, risks, and having client choose in writing.

My Staking Client Advisory Process

Here’s my step-by-step process:

Step 1: Initial Consultation (30 minutes, $150 fee)

Cover:

  • How staking works (many clients don’t understand)
  • Tax positions available (conservative, moderate, aggressive)
  • Risks of each position
  • IRS enforcement likelihood
  • Jarrett case status
  • My recommendation based on client risk tolerance

Deliverable: Written summary of discussion

Step 2: Tax Position Election Form

Client completes form:

STAKING TAX POSITION ELECTION

I, [Client Name], understand that staking reward taxation is legally uncertain. After consultation with my CPA, I elect the following tax treatment:

☐ Position 1 (Conservative): Income upon receipt
   I understand this creates immediate tax liability on illiquid income.

☐ Position 2 (Moderate): Income when accessible
   I understand I must document lock-up terms and IRS may disagree.

☐ Position 3 (Aggressive): Income only upon sale
   I understand this is contrary to IRS position, creates audit risk, and may result in penalties.

I acknowledge:
- CPA has advised me of risks of each position
- I am making this election voluntarily
- I understand IRS may disagree with my position
- I will pay any additional taxes, penalties, and interest if IRS prevails
- I will not hold CPA liable for my election

Client Signature: ________________ Date: ________
CPA Signature: __________________ Date: ________

This protects me from malpractice liability.

Step 3: Quarterly Tax Planning

For Position 1 clients (income upon receipt):

Quarterly meetings:

  • Review staking rewards received in quarter
  • Calculate estimated tax due
  • Prepare Form 1040-ES payment voucher
  • Remind client to transfer funds to tax savings account

Fee: $200/quarter (included in annual fee for high-value clients)

Step 4: Annual Return Preparation

Staking income reported on:

  • Form 1040, Schedule 1, Line 8z (“Other income”)
  • Description: “Cryptocurrency staking rewards”
  • Amount: Total for year

If taking aggressive position:

  • File Form 8275 (Disclosure Statement)
  • Attach detailed explanation
  • Cite Jarrett case and legal authorities

Step 5: Audit Defense (If Triggered)

If IRS audits:

  • Represent client in examination
  • Provide documentation (lock-up terms, FMV calculations, legal authorities)
  • Negotiate with IRS examiner
  • Appeal if necessary

Fee: $300/hour (separate from return preparation fee)

The Cash Flow Planning Issue

Tina mentioned clients don’t have cash to pay taxes. Let me share my client strategies:

Strategy 1: Automatic Liquidation

Setup:

  • Establish policy: Sell 50% of all staking rewards immediately upon receipt
  • Use proceeds to pay estimated taxes
  • Hold remaining 50% for appreciation

Example:

  • Receive 1 ETH in staking rewards ($3,000 value)
  • Immediately sell 0.5 ETH = $1,500 cash
  • Set aside for taxes: $1,200 (40% of $3,000 income)
  • Remaining $300 for client spending/savings
  • Hold 0.5 ETH for potential appreciation

Pros:

  • Ensures cash available for taxes
  • Reduces price risk (50% locked in at receipt price)
  • Disciplined approach

Cons:

  • Triggers immediate capital gain/loss (if sell price differs from receipt price)
  • Transaction fees on sale
  • May miss upside if price appreciates

Strategy 2: DeFi Borrowing

Setup:

  • Keep all staking rewards (don’t sell)
  • Borrow stablecoins against staked ETH as collateral
  • Use borrowed funds to pay taxes
  • Repay loan when eventually sell staking rewards

Example:

  • Receive 10 ETH in staking rewards ($30,000 value)
  • Deposit as collateral in Aave (DeFi lending protocol)
  • Borrow $12,000 USDC (40% of $30,000 = taxes due)
  • Pay taxes with borrowed USDC
  • Interest cost: ~8% APY = $960/year
  • Eventually sell ETH, repay loan

Pros:

  • Don’t have to sell ETH (maintain upside exposure)
  • Tax payment funded without selling

Cons:

  • Interest expense (~8-12% annually)
  • Liquidation risk if ETH price drops (need to maintain collateral ratio)
  • Smart contract risk (protocol could be hacked)
  • Complex DeFi mechanics (not for unsophisticated clients)

Only for sophisticated investors.

Strategy 3: Tax Loss Harvesting

Setup:

  • Review entire crypto portfolio for unrealized losses
  • Sell losing positions to realize capital losses
  • Use losses to offset staking income

Example:

  • Staking income: $30,000 (ordinary income)
  • Also hold SOL with $25,000 unrealized loss
  • Sell SOL, realize $25,000 capital loss
  • Capital loss offsets $25,000 of ordinary income
  • Net taxable income: $5,000
  • Tax saved: ~$10,000 (40% × $25,000)

Pros:

  • Reduces tax bill without needing cash
  • Uses existing portfolio losses

Cons:

  • Only works if you have losses to harvest
  • $3,000/year limit on deducting losses against ordinary income (carryforward rules)
  • Wash sale rules don’t apply to crypto (but be careful of economic substance)

The Institutional Client Problem

I have one institutional client (crypto fund) staking $50M. They’re earning $2.5M/year in staking rewards.

The tax issue:

  • Conservative position: $2.5M ordinary income × 37% = $925K/year in taxes
  • On illiquid staking rewards (can’t sell enough to cover without moving market)

What we did:

  1. Established clear tax policy:

    • Report as income upon receipt (conservative)
    • Document policy in fund offering documents
    • Disclose to LPs (limited partners)
  2. Cash flow planning:

    • Segregate portion of fund (20%) in liquid assets (USDC, US Treasuries)
    • Use liquid reserves to pay quarterly estimated taxes
    • Don’t rely on selling illiquid staking rewards
  3. Transfer pricing:

    • Fund has offshore entity (Cayman Islands)
    • Staking done through offshore entity
    • Complex transfer pricing analysis for management fees
    • US taxpayers still liable, but deferral strategies available
  4. Tax opinion:

    • Obtained written tax opinion from Big 4 firm ($50,000 cost)
    • Supports conservative reporting position
    • Penalty protection if IRS challenges

Cost: $200,000/year in tax compliance and planning for this one client.

Fee: $150,000/year (still profitable, but barely).

Questions for Fred and Tina

Fred: You mentioned liquid staking derivatives (stETH). How are you advising clients on the tax treatment of the ETH → stETH exchange? Taxable swap or non-recognition?

Tina: Have you had any clients where IRS ACCEPTED the “substantial restrictions” argument for locked staking rewards? Or does IRS always assert income upon receipt?

For everyone: How are you handling the timing difference between:

  • Staking rewards received (daily/weekly)
  • Exchange reporting (annual 1099-MISC)

If client receives 100 small staking rewards throughout year, but 1099-MISC shows one lump sum, how do you reconcile?

My Bottom Line

From practice management perspective:

Staking creates:

  • Client education burden (most don’t understand tax implications)
  • Legal uncertainty (Jarrett case, unclear IRS guidance)
  • Professional liability risk (could be sued regardless of position taken)
  • Cash flow challenges (clients lack funds to pay taxes)
  • Higher fees (complexity requires more time)

My recommendations for CPAs:

  1. Written advisory process (document everything)
  2. Client election form (protect yourself from liability)
  3. Conservative default (unless client knowingly elects otherwise)
  4. Quarterly tax planning (don’t wait until year-end)
  5. Charge appropriately (don’t undervalue your expertise)
  6. Decline bad-fit clients (if they won’t pay or won’t listen)

Staking is profitable service line IF you price correctly and manage risk. But don’t treat it as “just another 1099-MISC” - the complexity is real.

Alice Thompson, CPA
Thompson & Associates


P.S. - If anyone wants to see my “Staking Tax Position Election Form” template, happy to share. Also have “Staking Client Engagement Letter” language available.