"2.5.2 The “proof-of-stake” protocol

The accumulation of new virtual currencies can also be based on the blocking of existing virtual currencies for a time, in order to protect the virtual currency in question. The reward for this may be an increase of 5% per annum (or other comparable percentage) on top of a miner’s existing virtual-currency balance, paid on a daily basis (the proof-of-stake protocol). From the perspective of taxation, this is a direct gain on a previously held asset, and consequently, it is regarded as a capital gain.

The point in time when income is realized for purposes of taxation is when the miner gains possession of the new units of virtual currency. The income is valued at the market value of the virtual currency at that time. The amount of income received is also the gross acquisition cost for the newly acquired virtual currency. The acquisition cost of the miner’s old virtual currency remains unchanged. The same principle can also be applied to other situations where a taxpayer’s income is based solely on a gain on previously owned virtual currency. "