If you did something to earn tokens, the value of the tokens you received may be taxable. This is currently a gray area with the IRS.
In Jarrett et al vs United States of America, a Tennessee couple sued the IRS to get a refund for tax paid on staking income that they received but still held in their account.
The Justice Department offered to refund the money. But the IRS refused to say whether it would pursue other taxpayers who did not report staking rewards on their income tax return.
Exchanges and upgrades
Coin exchanges are reportable events with the IRs and may product gain or loss, so exchanging tokens are taxed based on the value of the old tokens at the time you received them against the fair market value of the new tokens at the time of exchange.
The upgrades would also be reportable. Most likely in an upgrade, the value of the old tokens would be incorporated into the value of the new tokens that you acquire due to the upgrade. It would depend on how the exchange worked.
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