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Dominion and control

The test the IRS uses for when crypto income is received: the moment you can sell, exchange, or transfer the asset. Rewards that are locked or unclaimable are not income until they can be accessed.

What is Dominion and control?

The test the IRS uses for when crypto income is received: the moment you can sell, exchange, or transfer the asset. Rewards that are locked or unclaimable are not income until they can be accessed.

Why it matters on your return

It sets the date and value of staking, airdrop, and reward income, which is often not the date the reward was announced. Recording the wrong date means the wrong value and the wrong year.

Example

A validator earns rewards subject to a 21-day unbonding period. The rewards are income when the period ends and they become transferable, at that day's price, not when they were credited.

Are unclaimed rewards income?

If you could claim them at any time, the IRS view is that you have dominion and control and they are income. If claiming is blocked, income waits until it is possible.

Source: Rev. Rul. 2023-14

Last reviewed September 17, 2026. Tax rules change; confirm current law before acting.

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