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Upcoming Changes in Crypto Tax: Navigating Form 1099-DA

The IRS is introducing Form 1099-DA, designated as "Digital Asset Proceeds from Broker Transactions," to bolster transparency and compliance for digital asset transactions. This new form mandates brokers to report transactions involving cryptocurrencies, non-fungible tokens (NFTs), and other digital assets, marking a significant shift in tax reporting in this rapidly expanding sector.

These reporting requirements will be in effect starting the 2025 tax year, with forms dispatched to taxpayers and the IRS by early 2026. Historically, digital asset reporting relied heavily on self-reported information, often leading to discrepancies and underreporting.

The Purpose and Impact of Form 1099-DA: Form 1099-DA is designed to enhance tax compliance by requiring standardized reporting from brokers, simplifying tax filing processes for digital asset investors. However, it also demands meticulous record-keeping to ensure accuracy.

Issuers of Form 1099-DA: The IRS requires "brokers," encompassing digital asset trading platforms, payment processors, and hosted wallet providers, to issue Form 1099-DA. Notably, decentralized finance (DeFi) platforms and self-custodial wallets generally do not fall under this requirement.

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Who Will Receive Form 1099-DA? U.S. taxpayers engaging in the sale, trade, or disposal of digital assets through registered brokers should expect to receive a Form 1099-DA in early 2026 for transactions conducted during 2025. This extends to individuals and businesses participating in activities like buying, selling, trading, mining, or staking digital assets. Real estate brokering entities must also report any digital asset involvement.

Content of Form 1099-DA: Brokers are required to detail various aspects of each digital asset transaction, including:

  • Payer and recipient identification.

  • Specifics of the transaction like asset name, quantity, date, time, and gross proceeds.

  • Cost basis (required for "covered securities" acquired after January 1, 2026). Reporting of cost basis is optional for the 2025 tax year.

  • Holding period.

  • Transaction type.

  • Fair market value (FMV).

  • Transaction fees.

  • Wash sales concerning tokenized securities.

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The annual variation in Form 1099-DA’s information specifics includes:

  • 2025 Tax Year (forms sent in early 2026) - Reporting is obligatory for gross proceeds from digital asset sales, exchanges, or disposals. Cost basis reporting in 2025 is optional for brokers.

  • 2026 Tax Year and beyond - Beginning with 2026, brokers must report additional detailed data, including gross proceeds, cost basis (for "covered securities"), acquisition and disposition dates, holding periods, and transaction specifics such as type and quantity.

Addressing the Cost Basis Reporting Challenges for 2025: The voluntary nature of cost basis reporting in 2025 presents potential issues. If unreported on Form 1099-DA, the IRS might assume a zero cost basis, potentially resulting in unreported income tax notices. Taxpayers should meticulously track digital asset transactions, noting acquisition dates and costs, fees, disposition dates, and selling prices to accurately complete Forms 8949 and Schedule D.

Special Rules for Stablecoins and NFTs: Specific digital asset types require tailored reporting rules:

  • Qualifying Stablecoins: From 2025 onward, brokers can report qualifying stablecoin transactions in aggregate if they exceed $10,000 annually.

  • Specified NFTs: Commencing in 2025, brokers must report if total sales of specified NFTs surpass $600 within the year, possibly in aggregate.

Utilization of Form 1099-DA for Filing Taxes: Information from Form 1099-DA plays a crucial role in preparing tax returns, akin to the manner stock transactions reported on Form 1099-B integrate into Form 8949 and Schedule D. This involves cross-verifying the 1099-DA with personal records to compute capital gains or losses and declare the reportable amount on Form 1040.

Optimizing Best Practices for Crypto Investors: Facing these changes, crypto investors should keep comprehensive transaction records, consider crypto tax software for tracking, and recognize possible gaps in broker reporting, notably concerning cost basis reporting in 2025. It remains essential to report any transactions not documented on Form 1099-DA. Keeping up with IRS regulations and seeking tax professional advice can aid in navigating the complex tax environment.

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IRS Digital Asset Disclosure Question: The IRS has been asking taxpayers, “At any time during the [return year], did you receive or dispose of any digital asset?” With the new Form 1099-DA, the IRS will have more data to substantiate taxpayers’ responses. It is paramount for taxpayers to ensure accuracy in answering and certify under penalty of perjury that the information in their tax return is correct.

Contact our office for further guidance and assistance in accurately reporting your digital asset transactions on your tax return.

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