This report argues that including proof-of-stake cryptocurrency block rewards in gross income when the reward tokens are first created results in inequitable taxation and would discourage U.S. taxpayers from participating in this new technology. The better approach is to tax reward tokens when...

New cryptocurrency staking "reward" tokens are not and should not be taxable when they are created. This article presents the basic economics of cryptocurrency staking and the applicable income tax law. It responds to counterarguments from the New York State Bar Association's Tax Section and...

Brief in support of Joshua Jarrett’s petition to the IRS seeking to establish that his cryptocurrency “staking rewards” are not taxable income until sold. Upon the IRS’s failure to respond to or rule on this petition, suit was filed in Joshua Jarrett v. United States, No. 3:21-cv-00419...

An overlooked provision — an amendment to tax code section 6050I — in the 2021 infrastructure spending bill will make receiving digital assets a felony if not reported correctly. This provision, which applies to all Americans who receive any kind of digital asset in the course of their trade...

This essay is about section 6050I of the tax code, the 1984 federal law that helped make cash obsolete. It’s important because the same law is now being aimed at digital assets, through an amendment to section 6050I that was signed into law on November 15, 2021.The United States government...

• An unsettled issue of immense practical and economic importance: how to tax the new “reward tokens” created in public cryptocurrency networks.• The wrong policy would drive innovation elsewhere. Fortunately, the correct policy is mandated by existing law: these new tokens – like all...

Stablecoins are digital assets whose value is pegged to that of fiat currencies, usually the U.S. dollar, with a typical exchange rate of one dollar per unit. Their market capitalization has grown exponentially over the last couple of years, from $5 billion in 2019 to around $180 billion in...

Stablecoins and money market funds both seek to provide investors with safe, money-like assets but are vulnerable to runs in times of stress. In this paper, we investigate similarities and differences between the two, comparing investor behavior during the stablecoin runs of 2022 and 2023 to...

Stablecoins and money market funds both seek to provide investors with safe, money-like assets but are vulnerable to runs in times of stress. In this paper, we investigate similarities and differences between the two, comparing investor behavior during the stablecoin runs of 2022 and 2023 to...