On June 5, the U.S. Tax Court issued a memorandum opinion in a closely watched case about the taxation of rewards from staked cryptocurrency tokens. In Paschall v. Commissioner, T.C. Memo. 2026-46, the Tax Court held that these rewards are includable in gross income
Introduction
Over the past several weeks, secondary markets for private company stock have surged back into the spotlight. High-profile issuers like Anthropic and SpaceX are reportedly seeing active demand for “secondary exposure” through special purpose vehicles (SPVs), forward contracts, and other synthetic structures.1 For