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Upcoming IRS 1099-DA: New Obligations for Crypto Transactions

As digital assets become increasingly mainstream, the IRS has introduced Form 1099-DA, "Digital Asset Proceeds from Broker Transactions," to standardize the reporting of digital asset transactions by certain brokers. This move prioritizes transparency and compliance within the dynamic cryptocurrency sphere, impacting transactions involving cryptocurrencies, NFTs, and other digital assets.

This requirement is poised to take effect for the 2025 tax year with brokers set to issue these forms to taxpayers and the IRS in early 2026. Historically, digital asset transaction reporting has heavily relied on self-reporting, a process susceptible to inconsistencies and underreporting.

The Purpose and Impact of Form 1099-DA: By mandating transaction reporting through Form 1099-DA, the IRS aims to bolster tax compliance and improve transaction reporting accuracy. This evolution in reporting seeks to aid investors in tax filing, although it concurrently requires meticulous record maintenance to ensure correct reporting.

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Who Must Issue Form 1099-DA? The obligation to issue Form 1099-DA falls broadly under "brokers," as defined by the IRS, which encompasses digital asset trading platforms, payment processors, and hosted wallet providers. However, decentralized finance (DeFi) platforms and non-custodial wallets are generally exempt from this requirement.

Who Will Receive Form 1099-DA? U.S. taxpayers involved in selling, trading, or disposing of digital assets via qualifying brokers can anticipate receiving Form 1099-DA in early 2026 for 2025 transactions. This applies to individuals and businesses engaging in digital asset transactions, including real estate reporting entities involved in digital asset transactions.

Information Included on Form 1099-DA: Brokers will report various details related to each digital asset transaction:

  • Payer and Recipient Identification
  • Transaction specifics such as asset name, quantity, date, time, and gross proceeds
  • Cost basis, which becomes mandatory for covered securities acquired post-January 1, 2026; it remains voluntary for the 2025 tax year
  • Holding period
  • Transaction type
  • Fair Market Value (FMV)
  • Transaction fees
  • Wash sales for tokenized securities

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The reportable details on Form 1099-DA differ based on the tax year:

  • 2025 Tax Year (forms sent in early 2026) - Gross proceeds from sales, exchanges, or other disposals of digital assets must be reported. The cost basis reporting remains optional for brokers in 2025.
  • 2026 Tax Year and beyond (forms sent from early 2027 onwards) - Brokers will be required to provide comprehensive information, including gross proceeds, cost basis for covered securities, acquisition and disposition dates, holding periods, and transaction specifics of the digital assets.

Understanding the Cost Basis Challenge for 2025: A critical consideration for 2025 is the voluntary nature of cost basis reporting by brokers. In its absence, the IRS may default to a zero cost basis, potentially triggering tax notices for underreported income. Thus, it's imperative for taxpayers to maintain thorough personal records of digital asset transactions, capturing acquisition dates, costs, fees, disposition dates, and sales proceeds. This documentation is crucial for accurately completing Forms 8949 and Schedule D.

Special Reporting Rules for Stablecoins and NFTs: Certain digital asset types are subject to specific reporting guidelines:

  • Qualifying Stablecoins: From 2025 onwards, brokers may report qualifying stablecoin transactions in aggregate if they exceed $10,000 annually.
  • Specified NFTs: Starting 2025, brokers are required to report NFTs if total sales surpass $600 annually, possibly in aggregate.

How Form 1099-DA is Used to File Taxes: Similar to stock transactions reported on Form 1099-B, data from Form 1099-DA is integral for tax return preparation. This includes reconciling the 1099-DA with personal records, calculating capital gains or losses, and reporting the final figures on Form 1040.

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Best Practices for Crypto Investors: Staying proactive, crypto investors need to meticulously record all transactions, leverage crypto tax software for tracking, and recognize potential broker reporting limitations, especially regarding cost basis in 2025. It's crucial to report all transactions, including those not indicated on a 1099-DA. Consulting a tax professional can navigate this evolving landscape effectively.

Addressing the IRS’s Question on Digital Assets: Form 1040 includes a "yes"/"no" query regarding digital asset transactions. Going forward, the IRS will validate taxpayer responses against Form 1099-DA filings. Taxpayers should answer with precision, acknowledging the penalties tied to perjury on the tax return.

For assistance in accurately reporting your crypto activities on your tax return, please contact our office.

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