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Essential Guide: Navigating the New 1099-DA Crypto Tax Reporting

Form 1099-DA, titled "Digital Asset Proceeds from Broker Transactions," represents a pivotal development from the Internal Revenue Service (IRS) aimed at increasing clarity and compliance within the burgeoning digital asset sector. This new mandate requires brokers to meticulously document transactions involving cryptocurrencies, non-fungible tokens (NFTs), and other digital instruments, facilitating a more transparent tax environment.

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The reporting obligations associated with Form 1099-DA will be applicable starting in the 2025 tax year, with these forms reaching taxpayers and the IRS by early 2026. Prior to this, digital asset reporting largely relied on self-disclosed information, which often led to misreporting and inconsistencies.

The Purpose and Impact of Form 1099-DA: The objective of Form 1099-DA is to streamline tax compliance and enhance reporting precision across the digital asset domain by compelling brokers to standardize transaction documentation. While this development may simplify the tax filing process for some investors, it also necessitates thorough record-keeping practices to maintain reporting accuracy.

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Who Must Issue Form 1099-DA? The obligation to issue Form 1099-DA falls on "brokers," as defined broadly by the IRS to include digital asset trading platforms, payment processors, and providers of hosted wallet services. Notably, decentralized finance (DeFi) platforms and non-custodial wallets generally do not have this requirement.

Who Will Receive Form 1099-DA? U.S. taxpayers engaging in the sale, trade, or disposal of digital assets through applicable brokers should expect a Form 1099-DA by early 2026 for 2025 activities. This includes individuals and businesses transacting in areas like mining, staking, and utilizing digital assets in real estate transactions.

What Information is Included on Form 1099-DA? Brokers will need to report comprehensive transaction specifics on Form 1099-DA, such as:

  • Payer and recipient identification details.

  • Asset-specific data encompassing name, quantity, date, time, and gross proceeds.

  • Cost basis (compulsory for "covered securities" acquired post-January 1, 2026). Reporting cost basis in the 2025 tax year remains optional for brokers.

  • Holding period.

  • Transaction type details.

  • Fair Market Value (FMV).

  • Transaction fees incurred.

  • Wash sales applicable to tokenized securities.

The specifics reported on Form 1099-DA will vary yearly.

  • 2025 Tax Year (forms sent in early 2026): For transactions in 2025, brokers must disclose gross proceeds from sales or exchanges of digital assets, with cost basis reporting being voluntary.

  • 2026 Tax Year and Beyond (forms sent in early 2027 and thereafter): As of 2026, brokers must report more detailed information, including the cost basis for covered securities, transaction dates, holding periods, and additional transaction particulars.

Understanding the Cost Basis Challenge for 2025: For 2025, with cost basis reporting being voluntary, there is a significant risk of the IRS deeming unreported cost basis as zero, potentially triggering tax notices for underreported income. To mitigate this, taxpayers must compile detailed personal records of digital asset transactions, including acquisition dates, costs, fees, and sale proceeds, which are vital for completing Forms 8949 and Schedule D accurately.

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Special Reporting Rules for Stablecoins and Non-Fungible Tokens (NFTs): Certain digital asset types have distinct reporting requirements:

  • Qualifying Stablecoins: Starting 2025, brokers may report qualifying stablecoin transactions in aggregate if exceeding $10,000 annually.

  • Specified NFTs: From 2025, brokers must report total NFT sales exceeding $600 per year, potentially in aggregate.

How Form 1099-DA is Used in Filing Taxes: The information from Form 1099-DA parallels stock transactions on Form 1099-B, which are transferred to Form 8949 and Schedule D. This includes reconciling form data with personal records, computing capital gains or losses, and documenting the results on Form 1040.

Best Practices for Crypto Investors: Given these modifications, digital asset holders should maintain precise records of all transactions, employ crypto tax software for tracking, and recognize potential discrepancies in broker reporting, particularly regarding cost basis in 2025. Notably, any transactions not reported on a 1099-DA must still be declared. Staying informed and consulting a tax professional is crucial in navigating these in-progress changes.

Answering the IRS Digital Asset Question: For several years, a binary question on Form 1040 queries taxpayers about receiving or disposing of digital assets. With brokers providing Form 1099-DA, the IRS can corroborate taxpayer responses against broker filings. Taxpayers must accurately answer the IRS's question, noting the penalties for perjury applicable upon signing their tax returns.

For further assistance with incorporating your crypto transactions into your tax return, please contact our office.

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