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Navigating the New 1099-DA Requirements for Crypto Reporting

Form 1099-DA, formally known as "Digital Asset Proceeds from Broker Transactions," represents the IRS’s latest initiative to standardize the reporting of digital asset transactions. This new protocol is set to increase transparency and compliance within the burgeoning digital asset market, capturing data on cryptocurrencies, NFTs, and other digital commodities.

The mandate to use Form 1099-DA officially starts in the 2025 tax year. Brokers will then provide these forms to both taxpayers and the IRS in early 2026. Historically, the reporting of digital asset transactions relied heavily on self-disclosure, often resulting in discrepancies and underreporting.

Form 1099-DA: Purpose and Impact: This form is designed to enhance tax compliance and the accuracy of transaction reports by demanding disclosures from brokers. This new reporting framework could streamline tax filing for some investors, although it requires meticulous record management to ensure accuracy.

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Who is Required to File Form 1099-DA? The filing responsibility for Form 1099-DA lies with "brokers" who facilitate transactions in digital assets. The IRS’s definition here is expansive, covering entities like digital asset exchanges, payment processing firms, and hosted wallet platforms. Notably, DeFi platforms and non-custodial wallets generally fall outside this obligation.

Recipients of Form 1099-DA include U.S. taxpayers involved with digital assets through eligible brokers. This entails individuals and businesses engaging in buying, selling, or trading, as well as activities like mining or staking. Additionally, real estate transactions using digital assets trigger reporting requirements if handled by a broker.

Details Required on Form 1099-DA: Brokers must report comprehensive transaction data, including:

  • Payer and recipient identification.

  • Transaction specifics, such as asset name, amount, date, time, and gross proceeds.

  • Cost basis (required for "covered securities" acquired after January 1, 2026). Voluntary for 2025.

  • Holding periods.

  • Transaction types.

  • Fair Market Value (FMV).

  • Transaction fees.

  • Wash sales for tokenized securities.

The information reported varies based on the tax year. For instance, in 2025, cost basis reporting is voluntary for brokers.

  • 2025 Tax Year - Brokers report gross proceeds from the sale, exchange, or disposal of digital assets.
  • 2026 Tax Year Onwards - Enhanced reporting captures gross proceeds, cost basis, acquisition and disposal dates, and additional transaction data.

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Challenges around Cost Basis in 2025: In 2025, the voluntary nature of cost basis reporting might lead the IRS to presume it as zero, potentially prompting notifications for underreported income. Taxpayers must thus diligently document their asset transactions, including acquisition costs and dates, fees, and proceeds. These records are crucial for correctly filling Forms 8949 and Schedule D.

Special Rules for Stablecoins and NFTs: Particular digital asset types have specific reporting rules:

  • Qualifying Stablecoins: Transactions exceeding $10,000 annually can be reported in aggregate from 2025 onwards.
  • Specified NFTs: Brokers must report NFTs if aggregate sales surpass $600 annually, starting in 2025.

Integrating Form 1099-DA into Tax Filings: The information on this form ties into tax returns similarly to stock-related Form 1099-B. This involves matching 1099-DA data with personal records, calculating capital gains or losses, and declaring these on Form 1040.

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Best Practices for Crypto Investors: In light of these regulatory changes, investors should:

  • Maintain detailed transaction records.
  • Consider crypto tax software.
  • Understand broker reporting limitations, especially cost basis in 2025.
  • Ensure unreported transactions are still declared.

Staying informed and consulting with tax professionals can aid in navigating these complexities.

IRS Queries on Digital Assets: Recently, Form 1040 includes a yes/no question about digital assets received or disposed of. With 1099-DA’s introduction, the IRS can verify taxpayer responses against broker filings, requiring careful answers to avoid discrepancies under penalty of perjury.

Please contact our office for assistance with your crypto transaction tax obligations and to ensure accurate compliance.

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