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Navigating the New 1099-DA Crypto Tax Reporting Requirements

The Internal Revenue Service (IRS) has introduced Form 1099-DA, "Digital Asset Proceeds from Broker Transactions," a pivotal new tax form designed to bring clarity and compliance to the burgeoning digital asset landscape. This initiative mandates that certain brokers report transactions involving cryptocurrencies, non-fungible tokens (NFTs), and other digital assets, aiming to boost transparency across the sector.

This requirement becomes effective for the 2025 tax year, with brokers tasked to issue these forms to both taxpayers and the IRS in early 2026. Previously, self-reporting was the norm, often leading to discrepancies and underreporting of digital asset transactions.

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Purpose and Impact of Form 1099-DA: The main objective of Form 1099-DA is to standardize reporting procedures, thereby facilitating increased tax compliance and accuracy. While this may simplify filing for some investors, it emphasizes the importance of meticulous record-keeping to ensure precision in reporting.

Obligation to Issue Form 1099-DA: "Brokers," as defined by the IRS, are obliged to issue Form 1099-DA. This group encompasses digital asset exchanges, payment processors, and hosted wallet providers, but typically excludes decentralized finance (DeFi) platforms and non-custodial wallets.

Recipients of Form 1099-DA: U.S. taxpayers involved in the sale, trade, or disposal of digital assets via brokers should expect Form 1099-DA in early 2026 for 2025 transactions. This includes activities such as buying, selling, trading, mining, or staking, as well as applicable real estate contracts involving digital assets.

Details Reported on Form 1099-DA: Essential data reported includes:

  • Payer and recipient details.

  • Transaction specifics such as asset identity, quantity, date, and gross proceeds.

  • Cost basis reporting (mandatory for "covered securities" bought post-January 1, 2026); optional in 2025.

  • Determination of holding periods, transaction types, fair market value (FMV), and transaction fees.

  • Wash sales for tokenized securities.

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The complexities of the 2025 tax year stem from the voluntary nature of cost basis reporting by brokers. If omitted, IRS might consider it zero, leading potentially to perceived underreporting. To mitigate this, taxpayers must maintain comprehensive records of their digital asset dealings, including all acquisition, disposition, and fee details, for accurate completion of Forms 8949 and Schedule D.

Special Rules for Stablecoins and NFTs: Different reporting rules apply:

  • Qualifying Stablecoins: Reports are required if transactions exceed $10,000 annually from 2025 onwards.

  • Specified NFTs: Starting 2025, a requirement arises to report NFT sales exceeding $600, even potentially in aggregate.

Utilizing Form 1099-DA for Tax Filing: Similar to stocks reported on Form 1099-B, data from Form 1099-DA is crucial for preparing tax returns, involving reconciliation with personal records and accurately reporting gains or losses on Form 1040.

Investor Best Practices: Given the landscape change, digital asset investors should adopt rigorous transaction record-keeping practices, consider employing crypto tax software for tracking, and remain cautious of broker reporting limitations, particularly regarding the 2025 cost basis. Even non-1099-DA reported transactions demand disclosure. Staying informed and seeking tax professional advice remains vital in navigating these changes.

IRS Inquiries on Digital Assets: The longstanding digital asset question on Form 1040 has seen a shift due to Form 1099-DA's introduction. Taxpayers must provide truthful, consistent responses to avoid discrepancies under penalty of perjury.

For further guidance on incorporating crypto transactions into your tax return, feel free to reach out to our office.

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