Sponsor
Mike Carey
Representative · R-OH
Representative · R-OH
Official title: To amend the Internal Revenue Code of 1986 to provide rules for taxation of income relating to the mining and staking of digital assets, and for other purposes.
Introduced June 8, 2026 by Mike Carey · Last progress June 8, 2026
The bill clarifies tax sourcing and definitions for crypto staking/validation and preserves trust treatment for many staking activities—reducing ambiguity and enabling Treasury guidance—while increasing near‑term tax liabilities, compliance burdens, and potential regulatory uncertainty for taxpayers and businesses.
U.S. and nonresident taxpayers and crypto users will get clearer sourcing and tax definitions for validation/staking/mining income, making filing, withholding, and cross-border sourcing determinations simpler and reducing reporting ambiguity.
Trusts and their beneficiaries will be allowed to engage in staking without automatically losing trust tax status, and trustees can retain or distribute staking rewards and use liquidity measures to meet redemptions, preserving pass‑through tax treatment and protecting beneficiary distributions.
The Treasury will have explicit authority to issue implementing regulations and to classify novel crypto activities, enabling administrative guidance that can resolve technical issues (attribution, partnerships) and produce consistent enforcement.
U.S. resident recipients of validation/staking rewards and other crypto income may face immediate U.S. tax liability and potential withholding obligations on receipt of rewards, increasing taxable income and cash‑flow burdens for many taxpayers.
Partnerships, trusts, and businesses may face materially higher compliance and reporting complexity (partner‑level sourcing, new statutory classifications, adapting prior informal practices), raising administrative costs and time burdens.
Broad statutory definitions combined with delegated Treasury discretion could produce regulatory uncertainty if the Secretary later alters classifications, creating shifting compliance expectations for taxpayers and firms.
Based on analysis of 4 sections of legislative text.
Adds sourcing rules and Code definitions for digital-asset validation income (staking/mining), clarifies partnership and trust treatment, and authorizes Treasury rulemaking.
This bill amends the Internal Revenue Code to create clear federal tax sourcing rules and definitions for digital assets earned from validating transactions (commonly called staking and mining). It designates when such acquisition income and certain deferred items are U.S.-sourced versus foreign-sourced, adds related partnership and qualified business income clarifications, and specifies that trust status is not lost solely because a trustee engages in staking activities. The Treasury Secretary is given rulemaking authority to refine and implement definitions and attribution rules. Effective dates generally apply to taxable years beginning after enactment (with the trust rule effective for taxable years ending after enactment).