Crypto Tax Update: Navigating the New 1099-DA Requirements

In an effort to improve transparency and compliance in the burgeoning digital asset arena, the Internal Revenue Service (IRS) is introducing Form 1099-DA, titled "Digital Asset Proceeds from Broker Transactions." This innovative tax form mandates that certain brokers report digital asset transactions, effectively altering the landscape of cryptocurrency taxation by encompassing cryptocurrencies, non-fungible tokens (NFTs), and other digital assets.

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Effective for the 2025 tax year, Form 1099-DA will see brokers sending these forms to both taxpayers and the IRS in early 2026. Historically, the onus was on individuals to self-report digital asset transactions, but this method often resulted in inconsistencies and a higher propensity for underreporting.

Objective and Impact of Form 1099-DA: The principal goal of this form is to heighten tax compliance and precision in digital asset reporting. By compelling brokers to disclose transactions, the form standardizes reporting practices and may simplify tax procedures for some investors. However, it simultaneously demands comprehensive record-keeping to ensure precise reporting.

Issuers of Form 1099-DA: This form is required from "brokers" engaged in digital asset sales or exchanges. The IRS broadly categorizes brokers to include digital asset trading platforms, payment processors, and hosted wallet providers, yet decentralized finance (DeFi) platforms and non-custodial wallets are typically exempt.

Recipients of Form 1099-DA: U.S. taxpayers involved in selling, trading, or disposing of digital assets via a qualified broker will receive a Form 1099-DA in early 2026 for their 2025 transactions. This group encompasses both individuals and businesses dealing in the buying, selling, trading, mining, or staking of digital assets. Real estate entities must also document transactions involving digital assets.

Details on Form 1099-DA: Brokers must furnish detailed data on each digital asset transaction:

  • Payer and recipient identification.
  • Transaction specifics like asset name, quantity, date, time, and gross proceeds.
  • Cost basis (required for "covered securities" acquired post-January 1, 2026), initially voluntary for 2025.
  • Holding period.
  • Transaction type.
  • Fair market value (FMV).
  • Transaction fees.
  • Wash sales for tokenized securities.
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The specifics of the information disclosed on Form 1099-DA vary with the tax year:

  • 2025 Tax Year (forms submitted early 2026) - Brokers are obliged to report gross proceeds from digital asset sales or exchanges. Cost basis reporting is optional for brokers in 2025.
  • 2026 Tax Year and Beyond (forms submitted early 2027 onwards) - Comprehensive data is mandatory, including gross proceeds, cost basis (for "covered securities"), acquisition and disposition dates, holding period, and other transaction details.

2025 Cost Basis Considerations: A noteworthy facet of the 2025 tax year is the voluntary nature of cost basis reporting by brokers. If omitted on Form 1099-DA, the IRS might default to assuming a zero basis, potentially resulting in tax notifications for understated income. Taxpayers should meticulously document their digital asset transactions to accurately complete Forms 8949 and Schedule D.

Specific Rules for Stablecoins and NFTs: Distinct reporting guidelines exist for certain digital asset types:

  • Stablecoins: Qualifying stablecoin transactions can be reported collectively if they surpass $10,000 annually from 2025 onwards.
  • NFTs: From 2025, if total sales of specified NFTs eclipse $600 for the year, brokers must report these transactions, potentially in aggregate form.

Utilizing Form 1099-DA for Taxes: Like stock transactions on Form 1099-B transferred to Form 8949 and Schedule D, Form 1099-DA data aids in preparing tax returns. This involves aligning the form's entries with a taxpayer’s records to calculate capital gains or losses for reporting on Form 1040.

Guidance for Crypto Investors: To adapt to these changes, digital asset investors should keep detailed transaction records, leverage crypto tax software for monitoring and computations, and note possible gaps in broker reporting, notably the cost basis in 2025. It remains crucial to report transactions not included on a 1099-DA. Staying informed and consulting a tax professional is advisable.

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IRS Digital Asset Questionnaire: In recent years, Form 1040 includes a question concerning digital assets: “At any time during [return year], did you: (a) receive (as a reward, award, or payment for property or services); or (b) sell, exchange, or otherwise dispose of a digital asset (or a financial interest in a digital asset)?” With brokers now issuing Form 1099-DA for digital asset sales or exchanges, the IRS can cross-reference taxpayers’ responses with broker-filed forms. Taxpayers certify their return's accuracy under penalty of perjury, so proper attention must be paid to answer this correctly.

For any queries or assistance with integrating your cryptocurrency transactions into your tax return, feel free to contact our office.

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