Dominion and control is the point at which you can sell, exchange or otherwise dispose of an asset as you choose. For staking rewards it marks the moment the units stop being an accrued or promised amount and become property you can actually use.
The test asks a practical question: can you do what you like with the units? Not whether they have been credited to a balance, and not whether you have chosen to move them, but whether anything stops you from selling, exchanging or transferring them if you decided to.
Staking produces several states where the answer needs work. Rewards can be accrued on-chain but unclaimed, claimable at any time with a transaction. They can be credited to an exchange balance but held under a lock. They can be added straight into a staked position that carries an unbonding delay. They can be released under a vesting schedule set by the protocol. Each of these is a different fact pattern and each gets its own answer.
Under Revenue Ruling 2023-14, when the taxpayer has the ability to sell, exchange or otherwise dispose of the rewards. That is the moment their fair market value goes into gross income, and the ruling applies the same test whether the taxpayer stakes directly or through an exchange.
Applied to the states above: rewards claimable at any time are, on that test, within your control before you claim them, because nothing prevents the disposal except your own decision to make it; the claim transaction records a choice rather than creating control. Rewards on an exchange balance that can be sold or withdrawn are under your control when credited. Locked staking rewards are not, until the lock lifts. Auto-compounded staking rewards sit inside a position you direct, and the unbonding delay attached to that position is the fact to analyse.
The ruling settles the test; it does not settle the facts. Whether a given protocol's rewards were disposable on a given day is a question about that protocol's rules, and the answer has to be established from them and documented. Withdrawal, claiming and sale are useful evidence of control and poor substitutes for it, because all three usually happen after control began, sometimes in a later tax year.
Once the date is fixed, everything else attaches to it: the USD fair market value is measured at that date, the units' basis equals that value, and their holding period runs from it.
A claim transaction used as the income date. Rewards that accrued from March to December, claimable throughout, get claimed the following January and imported as a single income event in the new tax year at January's price. The income lands in the wrong year, at the wrong value, and as one lot instead of the many that actually accrued, so the basis and holding period of every later disposal are wrong as well.
Read our Are Crypto Staking Rewards Taxed? Yes, Here's How in 2026
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