CoinVoice has learned that, according to News.bitcoin, the IRS issued a memorandum in October stating that even if an account is frozen, any cryptocurrency rewards received in the year they are received must still be taxed, even if the holder is later unable to access their funds.
The guide has been sent to Michael R. Fiore of the IRS Small Business/Self-Employed Division, which studied a hypothetical taxpayer (referred to as 'Taxpayer A') who held cryptocurrency in a bankruptcy platform account and received rewards, such as staking bonuses, before the account was frozen. [Original link]