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Stay Updated: New 1099-DA Crypto Reporting Requirements

Form 1099-DA, titled "Digital Asset Proceeds from Broker Transactions," is an innovative tax form introduced by the Internal Revenue Service (IRS) to address the requirements for reporting digital asset transactions. This pivotal form is intended to bring greater transparency to the burgeoning digital asset sector, focusing on cryptocurrencies, non-fungible tokens (NFTs), and other similar financial instruments.

This regulatory shift will officially initiate for the 2025 tax year, with the IRS and taxpayers receiving the requisite forms in early 2026. Historically, the digital asset space relied heavily on taxpayer self-reporting, a scenario that led to frequent inaccuracies and underreporting.

The Purpose and Impact of Form 1099-DA: Designed to bolster tax compliance, Form 1099-DA obligates brokers to rigorously report transactions, which promotes standardized reporting and could simplify the taxation process for investors. This change emphasizes the necessity for meticulous record-keeping to meet compliance requirements.

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Who Must Issue Form 1099-DA? The onus to issue Form 1099-DA lies with entities defined as "brokers" under the IRS's wide-ranging criteria, encompassing digital asset exchanges, payment processing entities, and hosted wallet services. Notably, decentralized finance (DeFi) platforms and non-custodial wallet providers are typically exempt from this requirement.

Who Will Receive Form 1099-DA? U.S. taxpayers engaging in sales, trades, or disposals of digital assets through qualifying brokers should anticipate receiving their Form 1099-DA by 2026, covering 2025 activities. This entails both individual and business entities participating in digital asset-related transactions. Entities involved in real estate transactions using digital assets must also report accordingly.

Information Required on Form 1099-DA: Broadened reporting including:

  • Payer and Recipient Identification.

  • Detailed transaction data, such as asset names, amounts, dates, times, and gross proceeds.

  • Cost basis (compulsory for "covered securities" after January 1, 2026, voluntary for 2025).

  • Holding periods.

  • Transaction category.

  • Fair Market Value (FMV).

  • Associated transaction fees.

  • Wash sales for tokenized securities.

The extent of information disclosed on Form 1099-DA will evolve based on the tax year:

  • 2025 Tax Year (forms dispatched in early 2026) - reports will include the gross proceeds of digital asset transactions, with an option for voluntary cost basis reporting.

  • 2026 Tax Year onwards (forms sent after 2027) - more robust reporting, including gross proceeds, mandatory cost basis (for "covered securities"), and comprehensive transaction details, is required.

Addressing the Cost Basis Conundrum for 2025: The choice for 2025 tax year brokers to omit cost basis disclosures poses potential challenges, as the IRS might default such basis to zero, possibly resulting in taxes warned for unreported earnings. Therefore, taxpayers should diligently document all aspects of their transactions.

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Special Reporting Protocols for Stablecoins and NFTs: Certain assets have unique reporting norms:

  • Qualifying Stablecoins: Transactions surpassing $10,000 in a year must be reported from 2025 onwards.
  • Specified NFTs: NFT sales exceeding $600 annually must also be reported beginning in 2025.

Utilizing Form 1099-DA in Tax Filings: Similar to stock transactions on Form 1099-B, the details from Form 1099-DA integrate with tax returns, where capital gains or losses are calculated and recorded on Form 1040.

Key Strategies for Crypto Investors: Given these new mandates, digital asset investors are advised to maintain thorough transaction records, contemplate adopting crypto tax software, and consult professionals to navigate potential reporting limitations, particularly regarding the cost basis in 2025. It is crucial that all transactions, even those not declared via 1099-DA, are fully documented. Staying updated and seeking expert guidance is essential to adapt within this swiftly changing landscape.

Responding to the IRS's Digital Asset Inquiry: Recent tax years have featured an apt “yes”/“no” query on Form 1040 addressing digital asset activities. With Form 1099-DA in use, the IRS can cross-reference taxpayer submissions against broker filings for greater scrutiny. Taxpayers are advised to answer accurately to avoid potential perjury implications.

For further assistance with incorporating your crypto dealings into your return, please feel free to contact us.

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