

Beginning with the 2025 filing season, we expect new reporting requirements for digital asset transactions to reshape the appearance of cryptocurrency activity on tax returns. As cryptocurrency exchanges and custodial digital asset trading platforms begin submitting standardized information to the Internal Revenue Service, crypto investors and businesses may face greater scrutiny if reported cryptocurrency transactions do not match their federal tax returns.
The Treasury Department and the Internal Revenue Service finalized regulations requiring certain cryptocurrency brokers to report digital asset transactions using Form 1099-DA. These rules were authorized under the Infrastructure Investment and Jobs Act and expand section 6045 reporting requirements to parts of the digital asset ecosystem that previously had limited standardized reporting.
Beginning on or after January 1, 2025, cryptocurrency brokers and certain digital asset intermediary entities must report proceeds from cryptocurrency transactions processed through custodial digital asset trading platforms and cryptocurrency exchanges. The reporting structure allows the IRS to compare broker records with tax filings submitted by crypto investors.
Traditional securities reporting already follows a similar framework through Form 1099-B. By introducing Form 1099-DA, regulators aim to increase visibility into crypto trading activity conducted through trading platforms, wallet hosting services, and other trading front-end service providers.
Form 1099-DA will capture key details about each digital asset transaction reported by cryptocurrency brokers. These reports may include sales, exchanges, and certain digital asset transfers conducted through custodial digital asset trading platforms that act as intermediaries in the transaction process.
Some decentralized finance activities and DeFi transactions may fall outside the initial reporting scope, especially when conducted through unhosted digital asset wallet providers or via direct smart contracts. Regulators have indicated that the regulatory environment for decentralized finance could evolve as the digital asset ecosystem grows.
Under current IRS guidance, cryptocurrency and other digital assets are treated as property for income taxes rather than currency. Notice 2014-21 established that convertible virtual currency follows property rules under the Internal Revenue Code.
A digital asset is broadly defined as a digital representation of value recorded on a cryptographically secured distributed ledger. This definition includes virtual currency, non-fungible tokens, governance tokens, and other blockchain-based assets stored in a digital asset wallet secured by private keys.
Because of this classification, many cryptocurrency transactions can trigger taxable events. Selling a digital asset for dollars, exchanging one token for another, or using a digital asset to pay for goods or services may generate capital gains or losses.
IRS guidance explains that several types of crypto transactions may create reporting obligations. Crypto trading on cryptocurrency exchanges, cryptocurrency mining rewards, cryptocurrency staking rewards income, and income earned through earn programs may all generate taxable income.
Taxable events can also occur through network activity, such as a hard fork that creates a new digital asset. When a taxpayer acquires control of a newly created asset, the value may be treated as income depending on the circumstances.
Because digital assets function as property, determining gains often requires calculating fair market value at the time of each on-chain transaction or off-chain transaction.
Cryptocurrency activity can appear in several forms when preparing a federal tax return. Capital gains or losses from cryptocurrency transactions are typically reported on Form 8949 and summarized on Schedule D as part of a U.S. tax return.
Income earned from digital assets may appear on Schedule 1 if the taxpayer receives rewards income or other payments tied to cryptocurrency activity. Trading platforms or cryptocurrency brokers may also report some payments on Form 1099-MISC.
The digital asset reporting question also appears near the top of Form 1040 and related individual tax forms such as Form 1040-SR and Form 1040-NR. Taxpayers must indicate whether they engaged in a digital asset transaction during the tax year.
Certain digital asset transfers or donations may require reporting on Form 8283 or Form 8282. Losses related to theft or disasters may be reported on Form 4684 under the theft loss rules described in Publication 547.
Taxpayers holding high-value digital assets on foreign trading platforms may also need to report those holdings on Form 8938. In some cases involving tokenized real estate or blockchain-traded contracts, property guidance in Publication 544 may apply.
Other specialized filings may arise depending on the transaction, including Form 709 for certain transfers or Form 8300 for large transactions reported under financial reporting rules.
Expanded digital asset reporting means the Internal Revenue Service will receive more detailed IRS administrative data on cryptocurrency transactions conducted through cryptocurrency brokers and trading platforms. If reported cryptocurrency transactions do not match the amounts reported on a taxpayer’s tax returns, discrepancies may lead to compliance reviews or IRS audits.
Accurate recordkeeping is essential for taxpayers participating in the digital asset ecosystem. Records should include purchase prices, digital asset transaction costs, transfer dates, and fair market value at the time of each digital asset transfer.
Tax professionals often recommend tracking cryptocurrency transactions using consistent accounting methods, such as the wallet-by-wallet method across multiple digital asset wallets. Maintaining detailed records helps taxpayers calculate net loss positions, comply with digital asset tax rules, and prepare accurate tax filings.
For taxpayers with complex crypto trading activity, consulting a tax professional or tax preparer may help reduce the risk of reporting errors or mismatches during IRS compliance checks.
By William Mc Lee, Editor-in-Chief & Tax Expert—Get Tax Relief Now