In a recent Chief Counsel Advice Memorandum, the IRS made clear that receipt of a “new” cryptocurrency (following a Hard Fork) results in gross income to the taxpayer (equal to its Fair Market Value) immediately upon the taxpayer’s dominion and control over the new cryptocurrency. It is an accession of wealth under IRC Section 61. It is the dominion and control however that results in the gross income inclusion. For example, if the taxpayer received the new cryptocurrency (following a Hard Fork), but the exchange from which he received it did not yet support the new cryptocurrency, then the taxpayer would not yet have full dominion and control and not yet have includable gross income.