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Prepare for IRS's New 1099-DA for Crypto Assets

As the digital landscape evolves, tax reporting is catching up with the advent of Form 1099-DA. This new mandate, labeled "Digital Asset Proceeds from Broker Transactions," is a crucial step by the IRS to standardize the reporting of digital asset transactions. Specifically designed to cover cryptocurrencies, non-fungible tokens (NFTs), and other digital assets, this form marks a significant shift towards transparency and compliance in the digital arena.

The effective tax year for Form 1099-DA is 2025, necessitating that brokers remit these forms to both taxpayers and the IRS by early 2026. Historically, digital asset transaction reports primarily relied on self-reported data, leading to potential discrepancies. Now, with this structured approach, the IRS aims to mitigate inconsistencies and enhance taxpayer compliance.

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The Objective and Consequences of Form 1099-DA: By enforcing standardized reporting for brokers, Form 1099-DA facilitates accurate tax filings. While this aids some investors by simplifying paperwork, it also underscores the importance of meticulous record-keeping. For those navigating the new landscape, this change presents an opportunity to improve fiscal clarity.

Eligible Parties for Issuing Form 1099-DA: According to the IRS, the onus of issuing Form 1099-DA rests on "brokers" involved in digital assets' facilitation, such as trading platforms, payment processors, and hosted wallet providers. Nevertheless, decentralized finance (DeFi) platforms and non-custodial wallets are generally exempt from this obligation.

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Recipients of Form 1099-DA: Any U.S. taxpayer engaged in selling, trading, or otherwise disposing of digital assets via a qualifying broker will receive Form 1099-DA by early 2026, reporting 2025 transactions. This extends to individuals and businesses active in digital asset commerce, including buying, mining, or staking digital currencies.

Details Captured on Form 1099-DA: This form requires comprehensive details of each transaction, including:

  • Payer and Recipient Identification
  • Transaction specifics: asset name, quantity, date, time, and gross proceeds
  • Cost basis (compulsory for "covered securities" acquired post-January 1, 2026); optional for the 2025 tax year
  • Holding period
  • Transaction type
  • Fair Market Value (FMV)
  • Transaction fees
  • Wash sales for tokenized securities

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It's vital to note that the information required changes by the tax year, with more exhaustive metrics implemented from 2026 onwards.

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The 2025 Cost Basis Dilemma: Voluntary cost basis reporting by brokers in 2025 means that any unreported data may be assumed as zero by the IRS. This assumption can result in tax notices for purportedly underreported income. Maintaining personal detailed records, including acquisition and disposition dates and costs, is critical for completing necessary tax forms accurately, such as Forms 8949 and Schedule D.

Unique Reporting for Stablecoins and NFTs: Special provisions apply for distinct asset classes. From 2025, qualified stablecoin transactions exceeding $10,000 annually can be aggregated in reports, while NFT sales surpassing $600 may also see aggregated reporting requirements.

Utilizing Form 1099-DA for Tax Filings: Information derived from Form 1099-DA will be employed in a manner akin to stock transactions reported via Form 1099-B, necessitating integration into Form 8949 and Schedule D to determine gains or losses for Form 1040 reporting.

Guidelines for Crypto Enthusiasts and Investors: Given these regulatory updates, crypto investors are advised to meticulously track transactions, consider leveraging specialized crypto tax software, and remain vigilant regarding reporting limitations, particularly concerning the initial voluntary cost basis reporting. Proactive engagement with a tax professional is recommended to navigate these changes adeptly.

IRS Inquiries Regarding Digital Assets: The IRS includes a binary question on Form 1040 regarding digital asset interaction per calendar year. With the integration of Form 1099-DA, the IRS can corroborate taxpayer answers with broker submissions. Correctly answering this section is imperative as it attests under penalty of perjury to the authenticity and completeness of return filings.

Should you have any questions or require assistance integrating your crypto transactions accurately in your tax filings, please contact our office for guidance tailored to your situation.

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