Decoding Form 1099-DA: Crypto Reporting for 2025

Form 1099-DA, titled "Digital Asset Proceeds from Broker Transactions," introduces a vital change in how digital asset activities are reported to the IRS. This new tax form mandates that brokers disclose transactions involving cryptocurrencies, non-fungible tokens (NFTs), and other digital assets. The implementation of Form 1099-DA is a strategic move to bolster transparency and adherence to tax obligations in the swiftly evolving digital asset sector by the IRS.

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This reporting requirement will be effective for the 2025 tax year, with brokers expected to distribute these forms to taxpayers and send counterparts to the IRS in early 2026. Currently, digital asset transactions largely rely on self-reported data, which has historically resulted in reporting discrepancies and underreporting.

The Impact of Form 1099-DA

Form 1099-DA is designed to boost compliance and enhance reporting precision in digital asset transactions by obligating brokers to standardize disclosures. While this might simplify tax filing for some investors, it does require meticulous record-keeping to ensure accurate data reporting.

Form Issuance Requirements

Brokers involved in the sale or exchange of digital assets are obligated to issue Form 1099-DA. The IRS defines "brokers" broadly to encompass digital asset trading platforms, payment processors, and custodially managed wallet providers. Notably, decentralized finance (DeFi) platforms and non-custodial wallets typically do not fall under this requirement.

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Recipient Expectations

U.S. taxpayers engaging in the sale, trade, or disposal of digital assets through qualifying brokers will receive Form 1099-DA for 2025 transactions by early 2026. This applies to individuals and businesses involved in actioning digital assets through activities such as buying, selling, trading, mining, or staking. Additionally, real estate transactions involving digital assets need to be reported.

Details Included on Form 1099-DA

Brokers must report extensive details for each digital asset transaction on Form 1099-DA, such as:

  • Payer and Recipient Identification
  • Transaction specifics including asset name, quantity, dates, times, and gross proceeds
  • Cost basis (mandatory for "covered securities" from January 1, 2026, onward, voluntary for 2025)
  • Holding period
  • Transaction type and fair market value (FMV)
  • Transaction fees and any wash sales involving tokenized securities

Year-Specific Reporting Requirements

  • 2025 Tax Year: Brokers report gross proceeds from digital asset sales. Cost basis reporting is voluntary during this period.
  • 2026 and Beyond: A broader range of data is mandatory, including cost basis, acquisition and disposition dates, holding periods, and more.

Managing the Cost Basis Challenge in 2025

The voluntary nature of cost basis reporting for 2025 means the IRS may assume a cost basis of zero without proper reporting, potentially causing underreported income tax notices. Taxpayers should therefore maintain comprehensive personal transaction records to accurately complete Forms 8949 and Schedule D.

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Reporting Rules for Specific Digital Assets

  • Stablecoins: Transactions exceeding $10,000 annually can be aggregated for reporting.
  • NFTs: Brokers must report total sales exceeding $600 annually, with potential aggregation.

Incorporating Form 1099-DA in Tax Filings

The data captured in Form 1099-DA plays a crucial role in tax preparation, akin to how stock transactions on Form 1099-B are reflected in Forms 8949 and Schedule D. This process requires reconciling the 1099-DA with taxpayers’ records, determining capital gains or losses, and accurately reporting these on Form 1040.

Tips for Crypto Investors

Given these upcoming changes, investors should maintain a comprehensive record of digital transactions, consider using crypto tax software, and acknowledge potential broker reporting limitations, especially concerning the cost basis in 2025. Non-reported transactions must still be declared. Staying informed and consulting a tax expert is advisable to navigate the changing landscape.

Addressing IRS Queries and Compliance

The IRS has queried taxpayers about digital asset transactions through Form 1040. As Form 1099-DA will corroborate these activities with the IRS, taxpayers must meticulously report digital activities.

Reach out to our office for assistance in accurately reporting your crypto transactions on your tax returns.

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