Understanding the New 1099-DA for Crypto Investors

The Internal Revenue Service (IRS) has introduced Form 1099-DA, known as "Digital Asset Proceeds from Broker Transactions," which must be utilized by certain brokers to document digital asset transactions. This initiative aims to enhance transparency and compliance within the rapidly advancing digital asset landscape by mandating the reporting of transactions that include cryptocurrencies, non-fungible tokens (NFTs), and other digital assets.

The requirements for filing Form 1099-DA will officially commence with the 2025 tax year, with brokers expected to dispatch the forms to taxpayers and the IRS by early 2026. Prior to this, the burden of reporting digital asset transactions lay primarily with the individuals, often resulting in inconsistencies and underreporting.

Purpose and Impact of the 1099-DA: The formation of Form 1099-DA is set to bolster tax compliance and accuracy in reporting digital assets by standardizing the process. This standardization should simplify tax filing for some investors but will require meticulous record-keeping to ensure precision in reporting.

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Obligations to Issue Form 1099-DA: "Brokers," as defined by the IRS—which encompasses digital asset trading platforms, payment processors, and hosted wallet providers—are required to issue Form 1099-DA. Conversely, decentralized finance (DeFi) platforms and non-custodial wallets are currently excluded from this requirement.

Recipients of Form 1099-DA: U.S. taxpayers involved in the sale, trade, or disposal of digital assets through a qualifying broker can anticipate receiving Form 1099-DA in early 2026 (accounting for 2025 transactions). This includes individuals and businesses engaged in buying, selling, trading, mining, or staking digital assets. Real estate entities handling transactions with digital assets are also under this reporting obligation.

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Components of the 1099-DA: This form necessitates brokers to include comprehensive details of each digital asset transaction, such as:

  • Identification of payer and recipient.

  • Details including asset name, quantity, date, time, and gross proceeds.

  • Cost basis (mandatory for "covered securities" post-January 1, 2026). For the 2025 tax year, brokers may voluntarily report this data.

  • Holding period.

  • Transaction type.

  • Fair Market Value (FMV).

  • Transaction fees.

  • Wash sales pertaining to tokenized securities.

The particulars reported on Form 1099-DA may vary by tax year.

  • 2025 Tax Year (forms sent in early 2026) - During this year, it's mandatory for brokers to report the gross proceeds from digital asset transactions. However, reporting the cost basis remains a voluntary action for brokers.
  • 2026 Tax Year and Beyond (forms sent in early 2027 and thereafter) - From the 2026 tax year forward, brokers must report extensive information, including gross proceeds, cost basis for "covered securities," transaction specifics, and more.

Cost Basis Reminder for 2025: A crucial consideration for the 2025 tax year is that brokers are not obliged to report the cost basis. If not reported, the IRS might assume it as zero, leading to underreported income notices. Hence, taxpayers should diligently maintain personal records, including acquisition dates, costs, fees, disposition dates, and sales proceeds, to accurately complete Forms 8949 and Schedule D.

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Special Reporting Guidelines: Certain digital assets require unique reporting methods.

  • Stablecoins: From 2025, aggregating transactions of qualifying stablecoins exceeding $10,000 annually becomes a broker's option for reporting.
  • Specified NFTs: Also starting in 2025, if total sales surpass $600 annually, brokers may aggregate these for reporting.

The Role of 1099-DA in Tax Preparation: The data from Form 1099-DA aids in tax preparation by simplifying the transfer of stock transaction details from Form 1099-B to Form 8949 and Schedule D. This involves reconciling the 1099-DA with personal records, calculating capital gains or losses, and reporting these on Form 1040.

Investor best practices: Given the new requirements, digital asset investors should keep thorough transaction records, utilize crypto tax software, and be alert to broker-reporting limitations, specifically around the 2025 cost basis. Unreported 1099-DA transactions must still be personally reported. Informed decision-making and consultation with tax professionals are key to effectively navigating this changing landscape.

Responding to the IRS Digital Asset Query: Recent years have seen a "yes" or "no" digital asset question on Form 1040. With the implementation of Form 1099-DA, the IRS can verify taxpayers' responses based on broker-filed forms. Accuracy in responding to this is critical, given the perjury penalties tied to tax return declarations. Thorough precision is necessary when answering the IRS's digital asset question.

For further guidance and comprehensive preparations regarding crypto transactions, please contact our office.  

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