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Essential Guide: New IRS Form 1099-DA for Crypto Assets

Understanding the IRS's newly introduced Form 1099-DA, titled "Digital Asset Proceeds from Broker Transactions," is crucial for those navigating the digital asset landscape. This tax form mandates brokers to report transactions involving cryptocurrencies, NFTs, and other digital assets, enhancing transparency and compliance across the industry.

The requirement for using Form 1099-DA officially begins in the 2025 tax year, with brokers tasked to send these forms to both taxpayers and the IRS in early 2026. Previously, digital asset reporting was primarily self-reported, often resulting in inconsistencies and underreported information.

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The Objective and Influence of Form 1099-DA: By obligating brokers to report digital asset transactions, Form 1099-DA seeks to boost tax compliance and enhance reporting accuracy. While it standardizes reporting protocols, it also demands meticulous record-keeping to ensure precise records come tax time.

Who Must Issue Form 1099-DA? The responsibility to issue Form 1099-DA lies with "brokers" who manage digital asset transactions. This definition encompasses digital trading platforms, payment processors, and hosted wallet services. Yet, decentralized finance (DeFi) platforms and non-custodial wallets generally don't fall under this requirement.

Recipients of Form 1099-DA will include U.S. taxpayers who conduct sales, trades, or disposals of digital assets through a qualifying broker. This includes participants in activities related to buying, selling, trading, mining, or staking digital assets. Real estate entities need to report if digital assets are involved in transactions.

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Details on Form 1099-DA: The form requires comprehensive details of each transaction, such as:

  • Identification information of both payer and recipient.

  • Specifics of the transaction including asset name, quantity, date, time, and gross proceeds.

  • Cost basis reporting, which becomes mandatory for "covered securities" acquired post-January 1, 2026; however, it's voluntary starting 2025.

  • Holding period and transaction type.

  • Fair Market Value (FMV) and transaction fees.

  • Wash sales for tokenized securities.

Reporting requirements vary by tax year:

  • 2025 Tax Year (files sent in early 2026) - Brokers have to report the gross proceeds of digital asset sales, exchanges, or disposals. Cost basis reporting remains voluntary.

  • 2026 Tax Year and beyond (forms sent in early 2027 and later) - Brokers will be compelled to provide detailed data, including gross proceeds and cost basis (for "covered securities").

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The Cost Basis Challenge of 2025: A notable condition for 2025 is the optional nature of cost basis reporting. If not reported, the IRS might assume a zero basis, potentially issuing tax notices for underreported earnings. Taxpayers should maintain detailed records of all digital asset transactions including the acquisition costs and relevant dates to support Forms 8949 and Schedule D.

Special Reporting Considerations: Different rules apply for certain digital assets:

  • Qualifying Stablecoins: For 2025 onward, brokers may aggregate report stablecoin transactions surpassing $10,000 annually.
  • Specified NFTs: As of 2025, NFT sales exceeding $600 should be reported, potentially in aggregate.

Using Form 1099-DA in Tax Filing: The details on Form 1099-DA integrate into tax returns similarly to stock transactions on Form 1099-B, ultimately reflecting on Form 8949 and Schedule D. This involves reconciling with taxpayers' records, thereby calculating gains or losses to report on Form 1040.

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Best Practices for Digital Asset Investors: With these changes imminent, digital asset investors should prioritize meticulous record-keeping, use advanced crypto tax software, and remain aware of potential broker reporting limitations, particularly in regards to cost basis until 2026. Moreover, all non-1099-DA reported transactions must still be disclosed. Staying informed or consulting a tax professional like those at Sullivan & Company CPA Inc., can be instrumental in navigating this evolving territory.

Answering IRS Inquiries: In recent years, Form 1040 includes a "yes/no" question related to digital asset involvement. With brokers filing 1099-DA forms, it becomes paramount to answer truthfully, considering the cross-checking possibilities by the IRS. Thus, precise and honest reporting is essential.

If you require assistance integrating your digital asset transactions into your tax return, reach out to our office for expert guidance and support.

Schedule Your Estate & Gift Consultation
Our team specializes in estate, gift, valuation, and forensic accounting matters. Book a confidential consultation to discuss your needs and get clear, actionable strategies.
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