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Critical Update: Preparing for the New 1099-DA Reporting for Crypto

The introduction of Form 1099-DA, titled “Digital Asset Proceeds from Broker Transactions,” marks a significant shift in how digital asset transactions are reported to the IRS. This form is designed to enforce greater transparency and compliance within the burgeoning digital asset market. It now requires brokers to report transactions involving cryptocurrencies, NFTs, and other digital assets in more detail than ever before.

Effective for the 2025 tax year, Form 1099-DA must be submitted by brokers to both taxpayers and the IRS in early 2026. Previously, the reporting of digital asset transactions was primarily self-regulated, which resulted in substantial inconsistencies and underreporting across the board.

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The Purpose and Impact of Form 1099-DA: The aim of this initiative is to bolster tax compliance and improve the accuracy of reports within the digital asset sector. By mandating broker reporting, the form promises to standardize processes and may streamline tax filing for some investors, albeit requiring meticulous record-keeping for accuracy.

Who Must Issue Form 1099-DA? The obligation rests on brokers, as broadly defined by the IRS to include digital asset trading platforms, payment processors, and hosted wallet providers. Notably, this excludes DeFi platforms and non-custodial wallets from reporting obligations under this form.

Who Will Receive Form 1099-DA? U.S. taxpayers engaging in the sale, trade, or disposal of digital assets through applicable brokers should anticipate receiving a Form 1099-DA in early 2026 for transactions undertaken in 2025. This encompasses individuals and entities involved in buying, selling, trading, mining, or staking digital assets, as well as real estate transactions that employ digital assets.

Information Reported on Form 1099-DA: Details required include the identification of payers and recipients, transaction specifics such as asset name, quantity, dates, times, gross proceeds, cost basis for covered securities acquired post-January 1, 2026, holding periods, transaction types, fair market value, fees, and wash sales for tokenized securities.

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Cost Basis and Reporting Complexity for 2025: Particularly for the 2025 tax year, when cost basis reporting is voluntary, brokers might not provide this data, prompting the IRS to potentially assume a zero basis. This could result in erroneous tax obligations. Taxpayers should maintain detailed personal transaction records to submit accurate Forms 8949 and Schedule D.

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Special Rules for Stablecoins and NFTs: Special rules apply for certain digital asset types. From 2025 onwards, brokers can report qualifying stablecoin transactions exceeding $10,000 annually in aggregate. For specified NFTs, total sales exceeding $600 annually must also be reported.

Integrating Form 1099-DA into Tax Filings: Form 1099-DA operates in a manner consistent with Form 1099-B for stock transactions, facilitating data transfer onto Form 8949 and Schedule D. Taxpayers should reconcile this with their records to accurately calculate capital gains or losses for Form 1040.

Recommended Practices for Crypto Investors: It is imperative for cryptocurrency investors to maintain comprehensive transaction records, consider leveraging crypto tax software, and remain cognizant of possible reporting shortcomings, especially regarding the cost basis for the 2025 provision. Transactions unreported on Form 1099-DA are nonetheless reportable. Staying informed and consulting with a tax professional can aid in navigating this evolving landscape smartly.

Addressing IRS Inquiries on Digital Assets: With the introduction of Form 1099-DA, the IRS can now corroborate responses to their digital asset inquiry on Form 1040 with the information provided by brokers. This enhances accuracy in tax reporting, and it is crucial to answer the IRS questions truthfully under penalty of perjury.

For further queries or specialized assistance in incorporating your crypto dealings on your tax return, do not hesitate to contact our office.  

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We solve tax problems for individuals and help tax pros solve tax problems for their clients.
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