A token whose redeemable underlying value changes as rewards accrue, while the number of tokens held generally stays constant.
Because the token count does not change, no new units arrive and the income view is harder to apply as rewards accrue. The common position defers recognition until the token is redeemed or sold, when the appreciation is realized as gain. Consistency between rebasing and reward-bearing positions matters when you hold both.
Under common practice, yes: rebasing tokens produce income as units arrive; reward-bearing tokens produce gain on disposal. The IRS has not addressed either.
Source: No IRS guidance as of September 2026; IRS Notice 2014-21 (property treatment)
Last reviewed September 18, 2026. Tax rules change; confirm current law before acting.
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