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Upcoming 1099-DA Crypto Reporting Changes: What You Need to Know

In a move to bolster transparency and compliance in the burgeoning digital asset landscape, the IRS introduces Form 1099-DA, "Digital Asset Proceeds from Broker Transactions." This new tax form mandates certain brokers to report transactions involving cryptocurrencies, NFTs, and other digital assets, marking a significant shift in how digital asset transactions are reported.

The Form 1099-DA reporting requirements become effective for the 2025 tax year, with forms being sent to taxpayers and the IRS in early 2026. Previously, the onus was largely on self-reporting by taxpayers, often leading to discrepancies and underreporting.

The Purpose and Impact of Form 1099-DA: By requiring broker-reported transaction data, Form 1099-DA aims to boost tax compliance and reporting accuracy in the crypto arena. While this standardization might facilitate tax filing for some, it also demands meticulous record-keeping from involved parties to ensure precise reporting.

Who Must Issue Form 1099-DA? The IRS defines "brokers" broadly to include digital asset trading platforms, payment processors, and hosted wallet providers, all required to issue this form. However, decentralized finance (DeFi) platforms and non-custodial wallets generally fall outside this requirement.

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Who Will Receive Form 1099-DA? U.S. taxpayers engaged in selling, trading, or disposing of digital assets via a qualifying broker should prepare to receive Form 1099-DA in early 2026. The form encompasses individuals and businesses involved in diverse digital asset activities. Additionally, real estate reporting entities must report when digital assets are utilized in transactions.

Included Information on Form 1099-DA: Brokers must report specifics of each digital asset transaction, such as:

  • Payer and Recipient Identification.

  • Transaction details — including asset name, quantity, date, time, and gross proceeds.

  • Cost basis (mandatory for "covered securities" acquired after January 1, 2026) — reporting for 2025 is voluntary.

  • Holding period.

  • Transaction type.

  • Fair Market Value (FMV).

  • Transaction fees.

  • Wash sales for tokenized securities.

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The data reported on Form 1099-DA differs by tax year:

  • 2025 Tax Year (forms dispatched in early 2026) - Requires brokers to report gross proceeds from digital asset sales, exchanges, or other dispositions. Cost basis reporting remains optional.

  • 2026 Tax Year Onwards (forms dispatched from early 2027) - Expands reporting to include gross proceeds, cost basis for "covered securities," acquisition and disposition dates, holding period, and comprehensive transaction details.

Understanding the Cost Basis Challenge for 2025: A critical consideration for 2025 is that broker cost basis reporting is voluntary. Without this data, the IRS might assume a zero cost basis, leading to possible tax discrepancies. To avert this, taxpayers must meticulously document digital asset transactions, detailing acquisition dates and costs, fees, and proceeds for forms such as 8949 and Schedule D.

Special Reporting Rules for Stablecoins and NFTs: Specific digital asset types encounter unique reporting stipulations:

  • Qualifying Stablecoins: For 2025 and beyond, brokers may report qualifying stablecoin trades in aggregate if they exceed $10,000 annually.

  • Specified NFTs: Starting in 2025, aggregate reporting is mandated for specified NFTs exceeding $600 in annual sales.

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Form 1099-DA & Tax Filing: The data on Form 1099-DA is crucial for tax returns, akin to the way stock transactions on Form 1099-B are transferred to Form 8949 and Schedule D. This involves reconciling the 1099-DA with individual records to compute capital gains or losses, then reporting the final amount on Form 1040.

Best Practices for Crypto Investors: With these changes in mind, digital asset investors must keep thorough transaction records, consider utilizing crypto tax software for tracking, and recognize potential gaps in broker reporting, particularly regarding 2025's cost basis. Transactions not included on a 1099-DA must still be reported. Consulting with a tax professional and staying updated can be vital in maneuvering through these evolving requirements.

Responding to the IRS Digital Assets Query: Recent years saw the Form 1040 posing the question: “Did you receive, sell, exchange or dispose of a digital asset?” With Form 1099-DA in play, the IRS can verify responses against broker filings. When affirming one's tax return under penalty of perjury, accuracy in answering the IRS's question becomes paramount.

For further guidance or assistance in accurately documenting your crypto transactions on tax returns, don't hesitate to reach out to Bryant CPA LLC.

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