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Stay Ahead with the New 1099-DA Digital Asset Reporting

As the digital asset landscape grows increasingly complex, the IRS has introduced a new tax form, Form 1099-DA, "Digital Asset Proceeds from Broker Transactions," to enhance reporting transparency and compliance. This form mandates that certain brokers report digital asset transactions, encompassing cryptocurrencies, non-fungible tokens (NFTs), and other digital holdings.

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Implementation Timeline: The reporting requirements for Form 1099-DA become effective for the 2025 tax year, with brokers distributing forms to taxpayers and the IRS in early 2026. Prior to this, digital asset transaction reporting largely relied on self-reported data, often resulting in discrepancies.

Purpose and Effects of the New Form 1099-DA: By standardizing reporting requirements, Form 1099-DA is poised to streamline tax filing procedures for investors. It empowers the IRS to verify reported data, promoting greater accuracy in the burgeoning digital asset sector.

Obligations for Brokers: The responsibility to issue Form 1099-DA falls on "brokers," defined broadly to include trading platforms, payment processors, and hosted wallet services. However, decentralized finance (DeFi) platforms and non-custodial wallets typically do not have this obligation.

Recipients of Form 1099-DA: U.S. taxpayers engaging in the sale, trade, or disposal of digital assets through qualifying brokers should anticipate receiving a Form 1099-DA beginning in early 2026, covering transactions from 2025. This alert targets individuals and businesses involved in various digital asset operations, including investment and real estate transactions involving digital currencies.

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Details Captured on Form 1099-DA: Brokers must report a comprehensive set of data for each digital asset transaction, comprising:

  • Payer and recipient identification;

  • Asset name, quantity, transaction date and time, and gross proceeds;

  • Voluntary cost basis reporting for the 2025 tax year and mandatory thereafter;

  • Holding period, transaction type, fair market value, transaction fees, and wash sale data for tokenized securities.

The reporting requirements evolve with each tax year:

  • 2025 Tax Year: Brokers must report gross proceeds, while cost basis reporting remains optional.
  • 2026 Tax Year Onwards: The reporting further expands, demanding disclosure of gross proceeds, cost basis, transaction type and details, and holding periods.

Cost Basis Implications for 2025: In cases where a cost basis is not indicated, the IRS might assume a zero value, leading to potential income underreporting notices. Therefore, taxpayers should maintain meticulous records of their digital asset dealings, including acquisition and sale data, to ensure precise tax reporting on Forms 8949 and Schedule D.

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Special Reporting Guidelines for Stablecoins and NFTs: Specific digital asset types, such as stablecoins and NFTs, have unique reporting criteria:

  • Stablecoins: For amounts exceeding $10,000 yearly, reporting can be aggregated.
  • NFTs: If sales exceed $600 annually, brokers may report in aggregate.

Using Form 1099-DA for Tax Filing: The form’s data aligns with tax reporting similar to stock transactions on Form 1099-B, which are then reflected on Forms 8949 and Schedule D during tax return preparation. It is crucial for taxpayers to reconcile Form 1099-DA information with their financial records to accurately report capital gains or losses on Form 1040.

Best Practices for Digital Asset Investors: Keep comprehensive records of all transactions. Utilize crypto tax software for accurate tracking, and consult with professionals familiar with digital asset taxation challenges. Despite changes in broker reporting, taxpayers should declare all financial activities involving digital assets.

Answering the Digital Asset Question for the IRS: Taxpayers should carefully answer the IRS’ Form 1040 question concerning digital asset transactions. With the advent of Form 1099-DA, the IRS can verify responses against broker-filed information. Signing the tax return commits a taxpayer to accuracy under penalty of perjury.

For guidance and assistance with crypto transaction filings, please reach out to our office.

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