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Navigating the New 1099-DA: Essential Steps for Crypto Compliance

As the IRS introduces Form 1099-DA, known as "Digital Asset Proceeds from Broker Transactions," the landscape for reporting digital transactions changes significantly. This new form mandates that specific brokers disclose digital asset dealings, aiming to boost transparency and adherence to tax regulations within the fast-evolving digital asset domain, covering cryptocurrencies, non-fungible tokens (NFTs), and other digital assets. Image 2

Commencing for the 2025 tax year, brokers will distribute Form 1099-DA to taxpayers and the IRS by early 2026. Previously, digital asset transaction reporting relied heavily on taxpayer-initiated data, which frequently led to discrepancies and underreporting.

The Purpose and Impact of Form 1099-DA: By obligating brokers to disclose transactions, Form 1099-DA seeks to heighten tax compliance and reporting precision in the digital asset arena. This standardization can simplify tax filings for certain investors but compels careful record-keeping to ensure precise reporting.

Who Must Issue Form 1099-DA? The duty to issue Form 1099-DA rests with "brokers," which the IRS defines broadly to include digital asset trading platforms, payment processors, and hosted wallet providers. Decentralized finance (DeFi) platforms and non-custodial wallets typically do not need to issue this form.

Who Will Receive Form 1099-DA? U.S. taxpayers engaged in selling, trading, or disposing of digital assets through a qualifying broker should watch for a Form 1099-DA in early 2026, covering 2025 transactions. This encompasses both individuals and businesses involved in buying, selling, trading, mining, or staking digital assets. Entities involved in real estate must report if digital assets partake in these transactions.

What Information is Included on Form 1099-DA? This form requires brokers to furnish detailed information for each digital asset transaction, such as:

  • Payer and Recipient Identification

  • Transaction specifics like asset name, quantity, date, time, and gross proceeds

  • Cost basis (mandatory for "covered securities" acquired post-January 1, 2026). Broker reporting of basis is optional for 2025

  • Holding period

  • Transaction type

  • Fair Market Value (FMV)

  • Transaction fees

  • Wash sales for tokenized securities

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The specifics reported on Form 1099-DA may vary based on the tax year:

  • 2025 Tax Year (forms sent in early 2026) - Brokers must report gross proceeds from all sales, exchanges, or disposals. Reporting of the cost basis will remain optional for brokers.
  • 2026 Tax Year and beyond (forms sent in early 2027 and later) - From 2026 onwards, brokers are obliged to provide detailed information including gross proceeds, cost basis (for "covered securities"), acquisition and disposition dates, holding period, and transaction type.

Understanding the Cost Basis Challenge for 2025: A key aspect for 2025 is the optional cost basis reporting by brokers. If the cost basis isn’t reported on Form 1099-DA, the IRS might assume it's zero, risking tax notices for underreported income. Taxpayers should maintain meticulous records of their digital asset transactions: acquisition dates and costs, fees, disposition dates, and sales proceeds, which are crucial for correctly completing Forms 8949 and Schedule D.

Special Reporting Rules for Stablecoins and Non-Fungible Tokens (NFTs): Specific reporting rules exist for certain digital asset types.

  • Qualifying Stablecoins: For 2025 and onwards, brokers may report qualifying stablecoin transactions collectively if annual totals surpass $10,000.
  • Specified NFTs: From 2025, if total sales of specified NFTs exceed $600 annually, brokers must report these, possibly in aggregate.

Utilizing Form 1099-DA in Tax Filing: Similar to stock transactions recorded on Form 1099-B, the data from Form 1099-DA is used for tax return preparation. This involves aligning the 1099-DA with a taxpayer’s records, computing capital gains or losses, and reporting the final amount on Form 1040.

Best Practices for Crypto Investors: Given these updates, digital asset investors should keep thorough transaction records, utilize crypto tax software for tracking and calculations, and be mindful of any limitations in broker reporting, particularly concerning the cost basis in 2025. Unreported transactions on a 1099-DA still require taxpayer disclosure. Remaining informed and consulting with a tax professional aids in navigating this shifting field.

Addressing the IRS Question about Digital Assets: A longstanding “yes”/“no” query on Form 1040 asks if, during the year, a taxpayer had any transactions involving digital assets, like receiving them as payment or selling them. With the issuance of Form 1099-DA, the IRS can better assess taxpayer responses to this question. The taxpayer affirms the truthfulness and completeness of the return under penalty of perjury, so precision in addressing this question is critical.

Feel free to reach out to our office for guidance and support in precisely including your crypto transactions on your tax return.

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