Month: January 2026

The Purpose and Impact of Form 1099-DA: Form 1099-DA aims to increase tax compliance and improve reporting accuracy in the digital asset space by requiring brokers to report transactions. This standardizes reporting and can simplify tax filing for some investors but also necessitates diligent record-keeping to ensure accurate reporting.

Who Must Issue Form 1099-DA? The reporting obligation for Form 1099-DA falls on “brokers” who facilitate the sale or exchange of digital assets. The IRS’s definition of a broker is broad and includes digital asset trading platforms, payment processors, and hosted wallet providers. However, decentralized finance (DeFi) platforms and non-custodial wallets are not generally required to issue this form.

Who Will Receive Form 1099-DA? U.S. taxpayers who sell, trade, or dispose of digital assets through a qualifying broker should expect to receive a Form 1099-DA in early 2026 (for 2025 transactions). This includes individuals and businesses involved in buying, selling, trading, mining, or staking digital assets. Real estate reporting entities must also report if digital assets are used in real estate transactions.

What Information is Included on Form 1099-DA? Form 1099-DA requires brokers to report detailed information about each digital asset transaction, including:

• Payer and Recipient Identification.
• Transaction details like asset name, quantity, date, time, and gross proceeds.
• Cost basis (mandatory for “covered securities” acquired after January 1, 2026). Broker reporting of basis is voluntary for the 2025 tax year.
• Holding period.
• Transaction type.
• Fair Market Value (FMV).
• Transaction fees.
• Wash sales for tokenized securities.

The information reported on Form 1099-DA varies depending on the tax year.

• 2025 Tax Year (forms sent in early 2026) – For 2025 transactions, brokers are required to report the gross proceeds from the sale, exchange, or other disposition of a digital asset. Reporting of the cost basis is voluntary for brokers in 2025.
• 2026 Tax Year and beyond (forms sent in early 2027 and later) – Starting with the 2026 tax year, brokers will be required to report more comprehensive information, including gross proceeds, cost basis (for “covered securities”), acquisition and disposition dates, holding period, and transaction details like the type and quantity of the digital asset.

Understanding the Cost Basis Challenge for 2025: A significant point for the 2025 tax year is the voluntary cost basis reporting by brokers. If the cost basis is not reported on Form 1099-DA, the IRS may assume it’s zero, which could lead to tax notices for underreported income. To prevent this, taxpayers must keep detailed personal records of their digital asset transactions, including acquisition dates and costs, fees, disposition dates, and sales proceeds. These records are necessary for accurately completing Forms 8949 and Schedule D.

Special Reporting Rules for Stablecoins and Non-Fungible Token (NFTs): There are specific reporting rules for certain digital asset types.

• Qualifying Stablecoins – For 2025 and later, brokers can report qualifying stablecoin transactions in aggregate if they exceed $10,000 annually.
• Specified NFTs – Starting in 2025, if total sales of specified NFTs exceed $600 for the year, brokers must report them, potentially in aggregate.

How Form 1099-DA is Used File Taxes: The information on Form 1099-DA is used when preparing tax returns similar to the way stock transactions reported on Form 1099-B are transferred to Form 8949 and Schedule D. This involves reconciling the 1099-DA with a taxpayer’s records, calculating capital gains or losses, and reporting the final amount on Form 1040.

Best Practices for Crypto Investors: Given these changes, digital asset investors should maintain detailed records of all transactions, consider using crypto tax software for tracking and calculations, and be aware of potential limitations in broker reporting, especially regarding cost basis in 2025. It is also important to remember that transactions not reported on a 1099-DA must still be reported. Staying informed and consulting a tax professional can help navigate this evolving landscape.

Answering the IRS Question about Digital Assets: For the last several years, a “yes”/”no” question on Form 1040 has been: “At any time during [return year], did you: (a) receive (as a reward, award, or payment for property or services); or (b) sell, exchange, or otherwise dispose of a digital asset (or a financial interest in a digital asset)?” Now that brokers will be issuing Form 1099-DA for the sale or exchange of digital assets, the IRS will be able to verify how taxpayers answer the question in light of the Form 1099-DA that was filed by the broker. When signing the tax return, the taxpayer signs under penalty of perjury that the information in the return is true, correct and complete. Care needs to be taken to correctly answer the IRS’ question.

Contact the Leesburg office 703-771-1818 or the Warrenton office 540-347-5681 if you have questions or need assistance with properly including your crypto transactions on your return.

Individuals age 50 and over can make additional annual “catch-up” contributions to salary reduction plans including 401(k) Deferred Compensation plans, 403(b) TSA plans, 457(b) Government plans and SIMPLE plans.

Age 50+ Catch-ups: For 401(k), 403(b) and 457(b) plans, the age 50 and over catch-up contributions, for plans that offer them, has been $7,500 for years 2023 through 2025 and for SIMPLE plans $3,500. These amounts are periodically adjusted for inflation.

Age 60 through 63 Catch-ups: New for 2025, the SECURE 2.0 ACT introduced an additional catch-up contribution for taxpayers aged 60 through 63. The thought being those are the ages nearing retirement when individuals have more available income that they can contribute to their retirement nest egg.

The SECURE 2.0 Act increases the catch-up contribution limits to the greater of $10,000 or 50% more than the regular catch-up amount, which results in a maximum catch-up for 2025 of $11,250 for those aged 60 through 63.  For SIMPLE plans, the computation is somewhat different and the maximum catch-up for 2025 is $5,250 ($6,350 if there are no more than 25 employees).

Mandatory Roth Contribution for Higher Incomes: Effective January 1, 2026, for employees with wages of more than $145,000 in the prior year from the employer sponsoring the plan, catch-up contributions must be designated as Roth contributions.

• Inflation-Adjusted: The $145,000 will be inflation-adjusted in future years.
• Employees Under the Threshold: Other employees who are eligible to make catch-up contributions may designate their catch-up contributions as a Roth contribution.
• Employer Doesn’t Have a Designated Roth Plan: If the employer doesn’t have a designated Roth plan, then catch-up contributions cannot be made by employees whose wages exceed the Roth catch-up wage threshold.
• No Prior Year Employment History: An employee who worked for the employer sponsoring the plan for only part of the preceding calendar year would be subject to the Roth catch-up requirement in the current year only if the employee had wages exceeding the full Roth catch-up wage threshold from the employer for the preceding calendar year.

Key Tax Planning Opportunities: Taxpayers can leverage this amendment as a strategic way to broaden their tax planning approaches. By contributing to Roth accounts, retirees have the advantage of reducing the risks linked to fluctuating future tax rates, as they can access funds from both taxed and untaxed accounts. Roth accounts provide the benefit of tax-exempt withdrawals of both the initial contributions and the investment gains, provided specific conditions, such as the employee being age 59½ and the five-year rule, are met. This capability enhances the appeal of Roth plans as a powerful instrument for estate planning, as they do not require distributions during the original owner’s lifetime.

• Explanation of the Five-Year Rule: A distribution will not be a qualified distribution if the distribution is made between the time of the first contribution to the plan and before five consecutive taxable years have been completed. Generally, the holding period is determined separately for each plan in which the employee participates. So, if an employee has elective deferrals made to Roth 401(k)s under two or more plans, the employee may have two or more different holding periods, depending on when the employee first had made contributions to a Roth 401(k) under each plan. Special rules apply when there have been rollovers of Roth plans. Check with this office for additional details.

Timing Considerations: Taxpayers should plan the timing of their Roth contributions wisely. Younger high-income employees could benefit from starting Roth contributions now to meet the five-year holding period before retirement, whereas those nearing retirement might need alternative strategies.

If you have questions or need assistance, please contact the Leesburg office 703-771-1818 or the Warrenton office 540-347-5681.