ethereum

Perspectives

The Ethereum upgrade: Musing about the Merge

(While keeping tax and accounting considerations in mind)

The Ethereum upgrade to proof-of-stake poses new issues for taxes and accounting. This paper explains the upgrade and its implications by considering such questions as: are there taxes on Ethereum from the upgrade; are Ethereum staking rewards compensation for services; when are rewards income; what are the valuation issues around rewards; and what about the fork?

Overview of the upgrade

The Ethereum upgrade—essentially a move to a proof-of-stake (PoS) from a proof-of-work (PoW) consensus mechanism for validation of ETH transactions—has been in the works since 2018. The upgrade and the rewards generated during the process are sure to have a number of complex and important tax and accounting implications. The objective of this point-of-view (POV) document is to lay out, in a direct and understandable form, some of the main issues and considerations participants and companies should address as a result of the upgrade.

The Ethereum upgrade: Musing about the Merge

A Discussion on the Merge with the Ethereum Foundation

In December 2022, Rob Massey (Global & US Tax Blockchain & Digital Assets Leader), Amy Park (US Audit & Assurance Blockchain & Digital Assets Partner), and Conor O’Brien (Blockchain & Digital Assets Tax Manager), sat down with Danny Ryan, core researcher from the Ethereum Foundation, for a thoughtful discussion on the Ethereum Merge. They dove into the technical specifics of the Merge and the tax and accounting implications and even discussed when the Shanghai upgrade is expected to launch. Check out the replay of their discussion above.

What is Ethereum?

The Ethereum blockchain is a public, permissionless blockchain that hosts transaction data and thousands of computer programs (“smart contracts”) that automatically implement transactions according to rules embodied in its code. Its native cryptocurrency, Ethereum (or “ETH”) serves a variety of functions: a store of value, a digital currency for making and receiving payments and conducting various financial transactions; the required means for paying transaction fees incurred for use of the Ethereum blockchain; and the mechanism for compensating “validators” who provide validation and other support services to the Ethereum blockchain.

The Ethereum blockchain is decentralized as it is not controlled by centralized authority; instead, copies of the blockchain are maintained on independent servers (“nodes”) all over the world. The operators of these nodes work together to validate each new “block” of data and to cryptographically lock the new block onto the existing blockchain. The rules and procedures for doing this are known as the “consensus mechanism.”

The new proof-of-stake consensus mechanism

On September 14, 2022, the Ethereum blockchain upgraded from its legacy proof-of-work consensus mechanism to the new proof-of-stake consensus mechanism that relies upon “staking” rather than “work” to verify and add new information to the Ethereum blockchain. That event is known as the “Merge.” New transactions or other data is broadcast to all nodes in the Ethereum blockchain network. Ethereum holders decide to become validators by staking (depositing) 32 ETH. The validators are collectively responsible for storing the Ethereum blockchain data, processing and validating transactions, and adding new blocks of data. In the Ethereum PoS mechanism, there are 32 slots in an epoch, each of which is assigned a validator and has the potential to form a block. Should a block be formed at a given slot, the assigned validator will have the responsibility for proposing the block. Validators whose blocks become part of the chain are awarded ETH for their efforts.

A validator’s assignment to a slot is done randomly, but the odds are weighted by the relative amount of ETH staked by each validator with no additional impact above 32 ETH. There is no economic benefit to staking more than 32 ETH per validator.

Definitions
Staking: A stake is a fixed amount of funds that are ‘committed’ to a blockchain by a validator in order to participate in block creation and attestation. On Ethereum 2.0, validators will stake a minimum of 32 ETH to the network and will be rewarded in ETH for their efforts.

Validator: An actor on Ethereum 2.0 who proposes and attests new blocks on the network. In proof-of-stake a validator stakes a minimum of 32 ETH in order to participate in maintaining the network. If a validator is chosen to attest the next block, they are rewarded in ETH as a percentage of their stake
.

Slots (32 slots = 1 epoch): A time period of 12 seconds in which a randomly chosen validator has time to propose a block. Each slot may or may not have a block in it.

 

If a validator’s block is incorporated into the blockchain and ultimately finalized, the validator receives a reward. If, however, the validator performs an action that could harm the functionality of the blockchain, such as proposing two blocks for their assigned slot, the would-be validator will be “slashed” and could lose part, or all, of their staked ETH. Self-interest and protection of one’s own assets are the chief incentives behind proof-of-stake. Moreover, it is expected that as the number of participants in the network increases, the more decentralized it will become and the safer from attack it will be.

What are the potential advantages of proof-of-stake for the Ethereum ecosystem? They include but are not limited to:

  • Lowering capital requirements in terms of both computing hardware and energy use (the Merge will likely reduce the blockchain’s energy consumption by more than 99%).
  • Providing for the ability of the protocol to not only reward good behavior but also punish explicitly bad behavior. As a result, proof-of-stake delivers a larger security margin on the capital securing the network.
  • Laying the foundation for the protocol to handle more transactions (increased throughput) via the implementation of subsequent upgrades.

'Beacon' and the transition to proof-of-stake

Upgrading from proof-of-work to proof-of-stake has been a difficult, lengthy, and multistep process. To evaluate and verify the many dimensions and issues of the new proof-of-stake technology, while maintaining the ongoing operations and data integrity of the Ethereum blockchain, Ethereum established the Beacon Chain in late 2020. Beacon is a “consensus layer” that initiated the proof-of-stake consensus logic and block gossip protocol while further exploration and testing took place. This is the chain that was merged with the existing PoW chain during the Merge. Beacon operated independently from, and in parallel with, the rest of the Ethereum blockchain (“Mainnet”) until the Merge.

Using traditional terms, one might characterize Beacon as a pilot that enabled validators and participants, under the guidance of the Ethereum community, to work through a number of different upgrade proposals to ensure proper functioning and effective scaling and security capabilities. As the community members tested and signed off on Ethereum Improvement Proposals (EIPs), they were incorporated into the main body of the Beacon Chain logic.

Validators who volunteered to participate in pre-Merge Beacon were initially required to stake a minimum of 32 ETH. To participate, validators have been obliged to “lock” their staked ETH (i.e., send the staked ETH to an address that does not allow its use or sale until the upgraded network is fully functional). Accordingly, voluntary participation in Beacon represented a serious commitment to the proof-of-stake program.

The Beacon participants used proof-of-stake to validate and record staking-related transactions on the Beacon consensus layer only; none of these transactions were recorded on Ethereum Mainnet. The transactions that were being recorded and validated included the following:

  • The establishment of new Beacon validators coming online (new tranches of 32 ETH)
  • The allocation of block rewards for successfully recording and validating blocks of transactions on the Beacon Chain
  • Penalties for poorly performing validators (i.e., inactive node)
  • Slashing for malicious validators with a minimum amount of 0.5 ETH for each occurrence (If a validator’s balance reached 16 ETH, they were removed from the validator set.) 

Block rewards in Beacon are subject to the restrictions and limitations applicable to staked ETH generally. 

The 'Merge' and its aftermath

The general upgrade of Ethereum to proof-of-stake on September 14, 2022, is known as the “Merge” because it represents the integration of the Beacon Chain with the Ethereum Mainnet. The nodes that served as Beacon validators now validate new blocks added to the Ethereum Mainnet. 

The Merge leaves at least two major issues unresolved. First, some nodes would like to continue a version of the Ethereum blockchain on a proof-of-work basis. This would typically result in a hard fork. But unlike a traditional fork, for the proof-of-work chain to continue, a number of things were required to happen:

  1. A different chain ID had to be established.
  2. Participants on this proof-of-work chain have to solve what is called “the difficulty bomb,” a mechanism that seeks to incentivize the participants to forgo the proof-of-work chain by systematically increasing the difficulty level of puzzles to be solved for mining. 
  3. Participants will have other upgrades to perform in order for this proof-of-work chain to continue to function effectively.

So, while a fork, it is unlike conventional forks. One might say there is an inherent contradiction here because this fork is at once new but also represents an older validation technology.

Second, the status of the staked ETH (both the initial stake and the block rewards earned by validating on the Beacon consensus layer) remains unresolved. The specs of the next scheduled upgrade to Ethereum (called “Shanghai”) represent the anticipated mechanisms or EIPs that will enable the participant stakers to access their original staked 32 ETH and/or take possession of their earned rewards to sell, exchange, etc. 

The Shanghai specs represent new specifications that are under discussion. But at this stage, the community of users has yet to reach a full consensus. In layperson's terms, that means the code that will “liberate” the 32 ETH and earned rewards has yet to be agreed upon, written, or implemented. But once the agreed Shanghai specs are implemented and integrated into the Mainnet (which is now proof-of-stake) they will enable participants to trigger a withdrawal to a designated address, and rewards and 32 ETH will no longer be reflected simply as a validator balance.

How to view the upgrade

With the September 14 Merge, the Ethereum Mainnet continues with its newly integrated proof-of-stake consensus mechanism. No transaction data or historical transaction data is lost in the Merge. All existing smart contracts still function without updates to the code. And with the Merge, the Beacon consensus mechanism and its validator nodes are recording every transaction on the blockchain, whereas, during its pre-merged state, Beacon was recording only staking-related transactions.

Ethereum has already undergone a series of upgrades over the years. Following the Mainnet Frontier launch in July 2015, there have been many upgrades from Bellatrix to Tangerine Whistle, and several of them bore the names of European capitals such as Berlin, London, and Istanbul. So, the Ethereum community has often envisioned that the Ethereum blockchain would undergo continuous improvements and upgrades. And although it began as a PoW-based blockchain, from the outset, changes were anticipated in terms of how it performed the consensus of the transactions.

A limited set of transactions was recorded on Beacon. In essence, its main goal was to test the new consensus mechanism in a live setting. Again, bear in mind that there was no transferability or any other kind of transaction—such as withdrawal—possible with the staked ETH and any earned rewards. So, it is worth repeating that when participants staked their 32 ETH on Beacon there was as yet no mechanism for recovering that 32 ETH, nor the rewards. And so they were, for all intents and purposes, “locked up.”

That reality raises a fundamental question: What do these rewards represent? With other proof-of-stake blockchains, participants can pull down these rewards and transfer or sell them. At present, with Ethereum, you may not.

Considerations: Tax and accounting

Let’s begin with the moment that somebody staked their 32 ETH on Beacon and created a validator node. What are the possible tax and accounting implications of that action? In other words, is there a taxable/revenue recognition event?

For tax purposes, under section 1001, gain or loss is realized in the sale or disposition of property. The pertinent question then becomes: Does participation in Ethereum staking result in a sale or disposition of the staked ETH?

As described above, when participants staked on the Beacon Chain, the ETH was locked into the established validator node, and the holder could not access the original 32 ETH or any rewards. The 32 ETH was locked for the time being and could only be withdrawn after a yet-to-be-determined set of future conditions and time. In other words, they were in limbo.

The question might therefore be asked whether staking 32 ETH represents a disposition of the ETH. In that respect, it is important to consider whether staking holders still have the benefits and burdens of ownership of the staked ETH.

Significantly, when staking on the Beacon Chain, the original owner of the 32 ETH remained the person who would have the ability to withdraw the staked ETH once the Shanghai specs enable withdrawals. Accordingly, such owner would be expected to retain both the economic benefit or detriment from appreciation or depreciation in those tokens and the right to control disposition of the tokens after withdrawals from staking are enabled. Moreover, no other person economically benefits from the staked 32 ETH or the staking rewards that result from staking while the ETH is still staked.

That said, platforms staking ETH on behalf of others should continue to evaluate their specific fact pattern for purposes of evaluating whether ETH staked on behalf of others should be recorded on their balance sheet or not. (Please consult Question 10 in the AICPA practice aid, Accounting for and auditing of digital assets, for the criteria for evaluation.) If the platform concludes that the ETH staked on behalf of others should not be recorded on its balance sheet, the platform should still consider whether it has a safeguarding obligation in accordance with Staff Accounting Bulletin No. 121. (Please consult Appendix B in the AICPA practice aid.)

Whether or not staking 32 ETH is considered to be a sale or disposition of the staked ETH, a further question that may be asked is whether the upgrade of the Ethereum network resulted in a taxable event for all holders of ETH, including those not participating in staking. In that regard, it may be pertinently observed that no exchange or disposition of the ETH is made by ETH holders generally throughout the process of the Merge. Holders of ETH will not be required to take any actions, be it a transfer or otherwise, for their ETH to benefit from the upgraded network. Ethereum holders are entirely passive during the Merge, and although the Merge changed key fundamental functions of the Ethereum blockchain, to the passive holders of ETH this will go largely unnoticed. The network has, in effect, upgraded around the assets. The existing smart contract network on Ethereum Mainnet continues to operate as intended upon implementation of the Merge.

It’s important to note that analogy plays a significant part in determining whether staking rewards on Ethereum represent compensatory or non-compensatory income in exchange for services. Section 83 and associated tax authorities should be considered in order to determine the answer as to whether rewards for staking are deemed to be compensation for services. And that may be a question of contention since apparently there is no clear counterparty to the staking activities.

Here are pertinent questions to help outline your analysis:

  • Do validation activities result in the performance of services if there is no service recipient counterparty?
  • Does the accrual of additional Beacon balance, as a result of earning block rewards, result in a transfer of “property” under section 83?
  • Is the Beacon balance considered “property” for purposes of section 83, and might that determination change during the evolution of the upgrade until the time withdrawals are enabled?

The following is a further elaboration on section 83 considerations. In the course of the validation efforts by the node owner and the consequent “earning” of rewards, was the network a service recipient/counterparty? If one were to conclude “yes” (i.e., that a nebulous network of unknown parties can be a counterparty), the logical next issue to consider is whether there is an actual transfer of property when a validator’s Beacon balance increases as a result of validating blocks of transactions. It may be difficult to conclude that ETH rewards are property, given their lack of transferability and the lack of clarity in future upgrades about enabling withdrawals. Given these factors, among others, and in light of the definition of property in Treasury Regulation 1.83-3, the rewards could be interpreted as an unsecured promise (without explicit legally binding terms) to receive ETH sometime in the future. This position should be evaluated on a continued basis as the upgrade process enables further functionality (e.g., withdrawals).

If not under section 83, should participants recognize income under any other Code sections, such as 61 or 451 for accrual basis taxpayers?

By examining the issue through the prism of these sections that address non-compensatory transfers of property, several questions may emerge:

  • Do the reward balances in themselves constitute “property” for general tax purposes, outside of section 83? This should be considered at each point in the continuum of the upgrade.
  • Does the earning of rewards result in an “ascension to wealth” for the taxpayer?
  • Does the earning of rewards represent a legal right to receive property at some point in the future?
  • If the taxpayer prepares applicable financial statements and recognizes an accrual of rewards for book accounting purposes, how should these be accounted for under applicable US tax rules, in particular section 451(b), which provides generally that gross income is recognized no later than when it is reported as book income?
  • What is the value of the property received to be recognized for income tax purposes?

In addressing those issues, it’s important to emphasize the following:

  • Under Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955), the court found that income is realized whenever there are “instances of [1] undeniable accessions to wealth, [2] clearly realized, and [3] over which the taxpayers have complete dominion.”
  • Rewards constitute or eventually give rise to “property” for tax purposes, but they are not “money” for tax purposes.
  • There’s also a question about the application of the claim-of-right doctrine since the ability to withdraw the rewards is not yet determined as the Shanghai specs have yet to be agreed.

From an accounting perspective, you need to consider whether staking rewards fall within the scope of ASC 606. This can be evaluated by considering ASC 606-10-15-3 to determine whether staking rewards meet the criteria of “consideration” received from a “customer”; and that consideration is a result of the entity’s ordinary activities. An entity may consider its counterparty to be the protocol itself and that the protocol may also be its “customer.” When making this determination, an entity would also consider whether staking is an ordinary activity of the entity.

All these different considerations point to the inherent complexity of understanding what is happening in this Ethereum upgrade and how these events are interpreted for tax and accounting guidance purposes. This further underscores the importance of careful selections in using analogies to existing rules. It is clear that there is no one-to-one correlation between US tax and US GAAP guidance on crypto taxes and accounting, and particularly as it relates to the Ethereum upgrade. That is why each participant should consider the specifics of their situation as they apply the accounting and tax rules and consult with their adviser.

Participants started receiving rewards on Beacon as early as December 2020. They continued earning rewards through the Merge, but these rewards, along with their staked 32 ETH, continue to be locked up with uncertainty as to when and how they will be unlocked. The questions become: Are these rewards taxable at the time they are received, and should revenue be recognized under US GAAP or IFRS? Those apparently simple questions go to the very heart of the matter: What does “receiving/earning rewards” really mean and imply?

As is often the case with crypto taxes, there is no hard and fast, or straightforward, reply.

The Merge was still pending when participants first staked on the Beacon Chain. And they had no ability to withdraw or exchange their ETH or rewards. So, it may remain a question of debate as to when the actual moment of “generating income” occurs for tax purposes. In fact, there may be a range of moments along the spectrum of the Ethereum upgrade when income generation occurs for tax purposes. It is worth noting, however, that the degree of uncertainty about the future course of events on the chain and its Mainnet should decrease over time as the community of participants works toward an agreed-upon solution for the Shanghai specs and their implementation. This is similar to the uncertainties surrounding the consensus mechanism that were clarified by the Merge. And with those events, it becomes ever more likely that participants will be able to access and transact with their accrued (constrained) rewards and benefits. Dominion and control of the rewards are an important consideration. But for those who stake directly, it may not be the single determining factor.

It is noteworthy that transaction fees on Ethereum are separate and distinct from staking rewards. They are a payment from a transacting party on the network and are immediately accessible upon delivery to the validator. Given the difference in nature between transaction fees and staking rewards, additional consideration should be given to the taxation of transaction fees.

Financial accounting considerations require evaluating whether revenue should be recognized for ETH rewards under ASC 606 (or IFRS 15). Practitioners should evaluate the facts and circumstances discussed earlier in considering, at any given time, whether revenue should be recognized. This includes, among other considerations, evaluating whether there is a contract with a customer (or protocol), and specifically what is the performance obligation of the entity in staking their ETH?

Under US GAAP, practitioners should evaluate the five criteria for revenue recognition under ASC 606-25-1. Specifically, entities should closely evaluate the final criteria regarding whether it is probable that the entity will collect substantially all of the ETH staking rewards received. Additional considerations for financial reporting may include the following:

  • Tracking and pricing the portion of rewards owed to end users by third-party validators
  • Evaluating whether a receivable (from third-party validators) or payable (to parties that stake ETH) should be recorded
  • When revenue is recognized, developing a methodology for pricing rewards received based on the facts and circumstances of the entity
  • Conducting ongoing impairment assessment of rewards from the Beacon Chain for financial reporting

In the final analysis, the decision whether to recognize revenue under ASC 606 also has to weigh the ongoing uncertainty connected with how and when the participants will access their initial stake and accrued (constrained) rewards. Ultimately that means, depending on the specific facts and circumstances of your company, you will determine when to recognize that revenue.

If participants are earning rewards prior to the point at which they may be withdrawn and they conclude it is income for tax or accounting purposes, they have an interesting question around valuation. The value of ETH changes with great frequency and is sometimes referenced as “volatile.” If rewards are claimed as income for tax purposes, prior to the time they become accessible, the value at that moment will most certainly differ from the value at the time they may be withdrawn. Further, at any given moment before the Shanghai specs are agreed and implemented, there remains uncertainty around the timing and the functionality of the withdrawal mechanism. These are important considerations for determining the valuation methodology used for tax purposes.

Another tax issue related to valuation also presents itself. The rewards accumulated on the Beacon Chain, and then after the Merge, are all fungible assets, and there is no way to segregate them by creating wallets or even tracking one from another while locked. That, of course, means there seemingly is not a mechanism for attaching tax basis to the rewards other than through the use of FIFO (first-in first-out). So once the Shanghai specs are agreed and implemented, withdrawals may necessarily be done according to FIFO.

On the accounting side, when it is deemed that the performance obligation is satisfied under ASC 606, you should determine the transaction price, given that staking rewards are non-cash considerations. And an entity should estimate the fair value of non-cash considerations. An entity can look to ASC 820 for guidance in evaluating how to determine the transaction price.

Finally, entities should consider subsequent measurement of these staking rewards. Since staked ETH generally meets the definition of indefinite lived intangible assets under ASC 820, participants and companies should perform an ongoing evaluation for impairment.

You may receive ETHW (W=proof-of-work) as part of the fork and the “new” proof-of-work protocol. And if you do, that may trigger a taxable event once you secure dominion and control—whether it’s at your own validation node or through another custodian. As mentioned above, the ETHW could be considered the new asset given the establishment of the new proof-of-work networks, separate and distinct from the primary and newly upgraded network or Ethereum Mainnet.

In that scenario, the entity should determine whether it meets the recognition criteria under US GAAP and whether the forked assets meet the definition of an asset. In other words: Is it a present right of the holder to an economic benefit and/or the ability to restrict access to the economic benefit?

Key considerations can include:

  • Can your company access that benefit? If using a third-party staking provider, do they support the fork or give you the ability to claim your asset? Thus, you may not be in a position to access the asset, and thus it might not meet the recognition criteria.
  • If it meets the recognition criteria, you should assess the value of the forked asset and determine the appropriate accounting for the forked asset.

One additional risk that exists when entering into transactions in ETHW is replay attacks. A replay attack can occur when two forked chains allow transactions to be valid across both chains. This is the case if the chain and the forked chain retain the same chain ID. In simple terms, a transaction authorized on one chain can also be presented on the other chain. And since your digital signature is the same on both chains, it can be accepted as a valid transaction on the other chain. Of course, whom you’re sending the assets to and the actual amount has to be exactly the same (or the signature would be invalid). But this still presents a risk.

A potentially effective way to protect against replay attacks is to move all assets via a replay-protection smart contract on both chains to new wallets dedicated to those chains. This could ensure unique signatures are used for transactions on each chain.

There are additional risks to be considered that relate to rollups and assets stored in bridges to other chains. During the Merge, these contracts were duplicated on both the PoW and PoS chains and, as such, can be vulnerable to replay attacks. This is a more complicated topic beyond the scope of this paper. But if you have significant assets in bridges, we recommend consulting with your advisers.

Conclusion

The Ethereum upgrade is a complex, ongoing process. And as the Ethereum community continues to work further on the details of the Shanghai specs and related EIPs, greater clarity is likely to emerge regarding the dynamics touched on in this POV. In the meantime, it’s important for all participants on the Ethereum platform and users of ETH to carefully consider the topics as outlined earlier. Tax and accounting considerations are complex, and the apparent answers are often subject to various interpretations and applications depending on the specific business and tax strategies that inform your or your company’s position and “stake.”

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Authors and contributors

Rob Massey
Global & US Tax Blockchain & Digital Assets Leader 
Deloitte Tax LLP

Tim Davis
Global & US Risk and Financial Advisory Blockchain & Digital Assets Leader
Deloitte & Touche LLP

Amy Park
US Audit & Assurance
Blockchain & Digital Assets Partner
Deloitte & Touche LLP

Mike Marzelli
US Audit & Assurance
Blockchain & Digital Assets Partner
Deloitte & Touche LLP

Seth Connors
Risk & Financial Advisory
Blockchain & Digital Assets Senior Manager
Deloitte & Touche LLP

Conor O’Brien
Blockchain & Digital Assets Tax Manager
Deloitte Tax LLP

Jun Ryu
US Audit & Assurance
Senior Manager
Deloitte & Touche LLP

Caitlin Hahn
US Audit & Assurance
Blockchain & Digital Assets Senior Manager
Deloitte & Touche LLP

Grant Anderson
Washington National Tax Managing Director
Deloitte Tax LLP

Nate Tasso
Washington National Tax Principal 
Deloitte Tax LLP

This publication contains general information only and Deloitte is not, by means of this publication, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This publication is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor.

Deloitte shall not be responsible for any loss sustained by any person who relies on this publication.

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