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Showing posts with label IRS Crypto Reporting. Show all posts
Showing posts with label IRS Crypto Reporting. Show all posts

IRS Form 1099-DA: The 2026 Crypto Heir Survival Guide

IRS Form 1099-DA: The 2026 Crypto Heir Survival Guide

Author: Davit Cho | Crypto Tax Specialist | CEO at JejuPanaTek (2012–Present) | Patent #10-1998821

Verification: Cross-referenced with IRS Treasury Decision 9992, Final Regulations on Digital Asset Reporting, and consultation with enrolled agents specializing in cryptocurrency taxation.

Last Updated: January 5, 2026

Disclosure: Independent analysis. No sponsored content. Contact: davitchh@gmail.com | LinkedIn

πŸ“Œ Industry Analysis & Compliance Insights

Based on our review of IRS guidance documents, tax professional consultations, and analysis of early 1099-DA implementations by major exchanges, the most critical challenge facing crypto heirs in 2026 is establishing accurate cost basis for inherited assets. From my perspective, the intersection of step-up basis rules and new broker reporting requirements creates both tremendous opportunity and significant risk—heirs who understand the system can save hundreds of thousands in taxes, while those who don't may overpay dramatically or face IRS scrutiny for inconsistent reporting.

 

January 1, 2026 marked a watershed moment in cryptocurrency taxation. On that date, IRS Form 1099-DA requirements went into full effect, requiring cryptocurrency exchanges and brokers to report not just gross proceeds from sales, but also cost basis information for every transaction. This seemingly technical change has profound implications for anyone who inherits cryptocurrency—understanding these rules can mean the difference between paying zero capital gains tax and paying hundreds of thousands unnecessarily.

 

The new reporting regime ends over a decade of cryptocurrency operating in a relative tax reporting vacuum. While crypto gains have always been taxable, enforcement was difficult when the IRS had no systematic way to track transactions. Form 1099-DA changes this equation entirely, giving the IRS comprehensive visibility into cryptocurrency sales across all major platforms. For crypto heirs, this creates both challenges and opportunities that demand careful attention.

 

This guide provides everything crypto heirs need to navigate the new 1099-DA landscape. We will examine how the form works, what information is reported, how inherited cryptocurrency receives special treatment, and the critical steps heirs must take to ensure accurate reporting and maximum tax efficiency. Whether you have recently inherited crypto or expect to in the future, understanding these rules is essential to protecting your family's digital wealth.

 

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IRS Form 1099-DA crypto tax reporting 2026 digital asset broker requirements

Figure 1: IRS Form 1099-DA represents the most significant change in cryptocurrency tax reporting since Bitcoin's creation. Beginning in 2026, brokers must report both gross proceeds and cost basis information, creating unprecedented visibility into crypto transactions for tax enforcement.

 

πŸ“‹ What is Form 1099-DA and Why It Matters

 

Form 1099-DA (Digital Assets) is the IRS's new information reporting form specifically designed for cryptocurrency and other digital asset transactions. Introduced through Treasury Decision 9992 and related guidance published in 2024, this form requires brokers—including cryptocurrency exchanges, certain wallet providers, and payment processors—to report detailed transaction information to both taxpayers and the IRS.

 

The form captures essential information including the type and amount of digital assets sold, the date of sale, gross proceeds received, cost basis (beginning in 2026), and whether the gain or loss is short-term or long-term. This information allows the IRS to match taxpayer returns against third-party reports, dramatically increasing the likelihood of detecting unreported cryptocurrency income.

 

For crypto heirs, Form 1099-DA presents unique considerations. When you inherit cryptocurrency, your cost basis is not the decedent's original purchase price—it is the fair market value on the date of death (or alternate valuation date). This stepped-up basis is one of the most valuable tax benefits in the entire tax code, potentially eliminating all capital gains that accumulated during the decedent's lifetime. However, exchanges may not automatically know that assets were inherited or what the correct stepped-up basis should be.

 

πŸ“Š Key Information Reported on Form 1099-DA

Data Field Description Heir Implication
Gross Proceeds Total sale amount in USD Reported to IRS automatically
Cost Basis Original acquisition cost May need heir correction for step-up
Date Acquired Original purchase date Changes to date of death for heirs
Date Sold Transaction date Determines holding period
Gain/Loss Character Short-term or long-term Inherited assets deemed long-term
Digital Asset Type Bitcoin, Ethereum, etc. Identifies specific assets

 

The significance of Form 1099-DA cannot be overstated. Prior to its implementation, cryptocurrency taxation relied heavily on voluntary compliance. Taxpayers were responsible for tracking their own transactions and reporting gains, and the IRS had limited tools to verify accuracy. Studies estimated that crypto tax compliance rates were below 50%, representing billions in uncollected revenue.

 

With 1099-DA reporting, the IRS now receives the same transaction data that taxpayers report. Their computers automatically flag discrepancies between reported income and 1099-DA information, triggering correspondence audits for mismatches. This matching program has historically been one of the IRS's most effective enforcement tools for other asset classes, and its application to cryptocurrency will dramatically increase compliance pressure.

 

The definition of broker under the new rules is expansive. It includes not just traditional cryptocurrency exchanges like Coinbase and Kraken, but also decentralized exchange front-ends that facilitate transactions, certain payment processors, and potentially some wallet providers. This broad definition ensures comprehensive reporting coverage across the cryptocurrency ecosystem.

 

πŸ“‹ Understanding 1099-DA is critical for heirs!
Review official IRS guidance now.

 

πŸ“… The 2024-2027 Implementation Timeline

 

IRS cryptocurrency regulation timeline 2024 2027 Form 1099-DA implementation dates

Figure 2: The phased implementation of IRS cryptocurrency reporting requirements from 2024 through 2027. Understanding this timeline is essential for heirs to anticipate what information exchanges will report and when cost basis tracking becomes mandatory.

 

The IRS implemented Form 1099-DA requirements through a phased approach, giving exchanges time to build the necessary systems while gradually expanding reporting obligations. Understanding this timeline helps heirs anticipate what information will be reported about their transactions and when.

 

In 2024, the Treasury Department published final regulations in Treasury Decision 9992, establishing the legal framework for digital asset broker reporting. This gave the cryptocurrency industry approximately 18 months to prepare systems and processes before reporting obligations began. The final rules addressed numerous comments from industry stakeholders and clarified many ambiguities in the proposed regulations.

 

For tax year 2025 (forms issued in early 2026), brokers were required to report gross proceeds from cryptocurrency sales on Form 1099-DA. This first phase established the basic reporting infrastructure without requiring the more complex cost basis calculations. Taxpayers received their first 1099-DA forms in January 2026, covering 2025 transactions.

 

πŸ“† 1099-DA Implementation Milestones

Date Milestone Heir Impact
July 2024 Final regulations published (TD 9992) Rules established for future reporting
January 1, 2025 Gross proceeds reporting begins Sales tracked but no basis reported
January 2026 First 1099-DA forms issued (2025 data) Heirs receive forms for inherited sales
January 1, 2026 Cost basis reporting begins Critical: basis may need heir correction
January 2027 Full 1099-DA with basis (2026 data) Complete reporting regime in effect
2027+ DeFi and additional broker coverage Expanded reporting scope

 

Beginning January 1, 2026, the full cost basis reporting requirement took effect. This means that for sales occurring in 2026 and later, exchanges must report both proceeds and cost basis, allowing the IRS to calculate gain or loss directly from the 1099-DA. This is the critical transition point for heirs, as exchanges may report incorrect basis for inherited assets unless properly notified.

 

The regulations also established a wallet-by-wallet or account-by-account tracking requirement beginning in 2026. This means brokers must track cost basis separately for each wallet or account, rather than using a universal pool method. For heirs who received inherited crypto transferred from the decedent's wallet, this creates an opportunity to establish the stepped-up basis correctly from the start.

 

Future phases will expand reporting to cover additional transaction types and potentially additional broker categories. The IRS has indicated that reporting for real estate transactions settled with cryptocurrency, certain decentralized finance activities, and non-fungible tokens may be addressed in subsequent guidance. Heirs should monitor these developments as the cryptocurrency regulatory landscape continues to evolve.

 

 

πŸ’° Cost Basis Tracking: The New Requirements

 

Cryptocurrency cost basis tracking 1099-DA reporting requirements wallet exchange data

Figure 3: The new cost basis tracking requirements under Form 1099-DA create a complex web of data flows between wallets, exchanges, and the IRS. Heirs must ensure their stepped-up basis is correctly recorded within this system to avoid overpaying taxes.

 

Cost basis tracking represents the most technically complex aspect of Form 1099-DA compliance. Under the new rules, brokers must track the cost basis of each digital asset unit from acquisition through sale, maintaining records that can span years or even decades. For cryptocurrency purchased directly on an exchange, this is relatively straightforward. For inherited cryptocurrency, it requires special handling.

 

The regulations require brokers to use a wallet-by-wallet tracking method beginning in 2026. Each wallet or account is treated as a separate pool of assets with its own cost basis records. When cryptocurrency is transferred between wallets (including transfers from a decedent's account to an heir's account), cost basis information should transfer with it. However, the mechanics of this transfer depend on both the sending and receiving platforms' capabilities.

 

For inherited cryptocurrency, the cost basis rules are fundamentally different than for purchased crypto. Under IRC Section 1014, property acquired from a decedent receives a stepped-up basis equal to fair market value on the date of death (or alternate valuation date if elected). This means the heir's cost basis is NOT the decedent's original purchase price—it is the value at death. This distinction is worth potentially hundreds of thousands of dollars in tax savings.

 

πŸ“ˆ Cost Basis Methods Under 1099-DA

Method Description Heir Consideration
FIFO (First In, First Out) Oldest units sold first Default method if none specified
LIFO (Last In, First Out) Newest units sold first May benefit recent inheritance
HIFO (Highest In, First Out) Highest cost units sold first Minimizes current gain
Specific Identification Choose exact units to sell Maximum flexibility for heirs
Wallet-by-Wallet (2026+) Separate tracking per account Inherited wallet gets stepped-up basis

 

The specific identification method offers the greatest flexibility for heirs. By specifically identifying which units are being sold, heirs can choose to sell inherited units (with stepped-up basis) before units purchased personally (with lower original basis). This allows strategic tax planning to minimize current-year gains while preserving lower-basis units for future sales or further appreciation.

 

When cryptocurrency is transferred from a decedent's exchange account to an heir's account, the exchange may or may not automatically recognize the stepped-up basis. Some exchanges have implemented inheritance transfer procedures that allow heirs to submit death certificates and establish correct basis. Others may transfer the decedent's original basis records, requiring the heir to manually adjust on their tax return.

 

Documentation is critical for heirs claiming stepped-up basis. The IRS may request evidence supporting the fair market value used as basis, including the date of death, the specific assets inherited, and the valuation methodology. Heirs should retain death certificates, estate documentation, exchange records showing values on the death date, and any appraisals or valuations prepared for estate purposes.

 

For cryptocurrency held in self-custody wallets rather than exchanges, cost basis tracking becomes the heir's responsibility entirely. Hardware wallets and software wallets do not report to the IRS, and no 1099-DA is generated for transfers between self-custody addresses. Heirs who receive inherited crypto directly to their own wallet must maintain their own records of stepped-up basis for eventual reporting when the assets are sold through a broker.

 

 

πŸ›️ How Inherited Crypto is Treated Differently

 

Inherited cryptocurrency tax treatment versus purchased crypto 1099-DA reporting differences

Figure 4: Side-by-side comparison of tax treatment for inherited versus purchased cryptocurrency. The step-up in basis provision under IRC Section 1014 can eliminate decades of accumulated gains, making inheritance dramatically more tax-efficient than lifetime gifts.

 

Inherited cryptocurrency receives fundamentally different tax treatment than purchased cryptocurrency, and understanding these differences is essential for heirs navigating Form 1099-DA. Three key distinctions apply: stepped-up basis, automatic long-term holding period, and special documentation requirements. Each provides significant tax advantages when properly understood and applied.

 

The stepped-up basis rule under IRC Section 1014 is the most valuable benefit for crypto heirs. When property is inherited at death, the heir's cost basis equals fair market value on the date of death—not the original purchase price. If a decedent bought Bitcoin at $1,000 and it was worth $100,000 at death, the heir's basis is $100,000. All $99,000 of appreciation during the decedent's lifetime is permanently excluded from capital gains taxation.

 

The holding period rule provides additional benefits. Regardless of how long the decedent held the cryptocurrency or how soon after death the heir sells it, inherited property is automatically treated as long-term. This means the preferential long-term capital gains rates (0%, 15%, or 20% depending on income) apply rather than ordinary income rates that can reach 37%. An heir could inherit crypto on Monday and sell it on Tuesday, and any gain would still qualify for long-term treatment.

 

πŸ’΅ Inherited vs. Purchased Crypto Tax Comparison

Factor Inherited Crypto Purchased Crypto
Cost Basis FMV at death (stepped-up) Actual purchase price
Holding Period Automatic long-term Must hold 1+ year for LTCG
Prior Gains Taxed No (eliminated at death) Yes (when sold)
1099-DA Reporting May need heir adjustment Reported automatically
Documentation Needed Death certificate, valuation Purchase records

 

Consider this example illustrating the dramatic tax difference. A parent bought 10 Bitcoin in 2015 for $3,000 total ($300 each). At their death in 2025, those 10 Bitcoin were worth $950,000 ($95,000 each). Their child inherits the Bitcoin with a stepped-up basis of $950,000. If the child sells immediately for $950,000, they owe zero capital gains tax. If the parent had sold before death, they would have owed approximately $225,000 in federal capital gains tax on the $947,000 gain.

 

The alternate valuation date election can provide additional benefits in declining markets. If the estate elects alternate valuation under IRC Section 2032, property is valued six months after death (or at disposition if sold earlier). If cryptocurrency values declined significantly after death, using the alternate valuation date as the heir's stepped-up basis could actually exceed the death date value, providing additional tax benefits when prices recover.

 

Contrast inherited crypto with gifted crypto, which receives carryover basis. If the same parent had gifted the 10 Bitcoin during their lifetime instead of leaving it at death, the child would inherit the parent's $3,000 basis. When the child eventually sells for $950,000, they owe capital gains tax on $947,000—the exact tax the step-up in basis would have eliminated. This distinction makes deathbed planning critical for appreciated crypto assets.

 

πŸ” Example: Tax Savings from Step-Up in Basis

Scenario Basis Sale Price Taxable Gain Tax (23.8%)
Parent Sells Before Death $3,000 $950,000 $947,000 $225,386
Child Inherits (Gift) $3,000 $950,000 $947,000 $225,386
Child Inherits (Death) $950,000 $950,000 $0 $0

 

 

⚠️ Common Mistakes Heirs Make with 1099-DA

 

The intersection of Form 1099-DA reporting and inherited cryptocurrency creates numerous opportunities for costly mistakes. Understanding these common errors helps heirs avoid overpaying taxes or triggering unnecessary IRS scrutiny. Each mistake represents real money lost or compliance headaches that proper planning could have prevented.

 

The most expensive mistake is accepting the 1099-DA basis without correction. When an heir inherits cryptocurrency on an exchange and sells it, the exchange may report the decedent's original basis rather than the stepped-up basis. If the heir simply reports the 1099-DA figures without adjustment, they pay tax on gains that should have been eliminated at death. This single mistake can cost tens or hundreds of thousands of dollars.

 

Failing to document stepped-up basis creates long-term problems. Even if an heir correctly claims stepped-up basis on their tax return, the IRS may request substantiation. Without death certificates, estate valuations, and records of the cryptocurrency's value on the date of death, the heir may be unable to prove their claimed basis. The IRS could then assess additional tax based on zero basis or the decedent's original basis.

 

🚨 Critical Heir Mistakes with 1099-DA

Mistake Consequence Solution
Accepting incorrect 1099-DA basis Overpaying tax by $100,000+ Adjust basis on Form 8949
No documentation of death date value Cannot prove stepped-up basis Record FMV immediately at death
Mixing inherited and purchased crypto Basis confusion, wrong tax Keep inherited crypto in separate wallet
Not notifying exchange of inheritance Wrong basis on future 1099-DAs Complete inheritance transfer process
Using wrong valuation date Higher or lower basis than entitled Confirm date of death vs alternate date
Ignoring 1099-DA entirely IRS matching notice, penalties Always report, adjust if needed

 

Mixing inherited cryptocurrency with purchased cryptocurrency in the same wallet or exchange account creates basis tracking nightmares. When the heir later sells, determining which units are inherited (with stepped-up basis) versus purchased (with original basis) becomes difficult. The safest approach is keeping inherited crypto in a separate account or wallet from personally acquired holdings.

 

Failing to complete the exchange's inheritance transfer process is surprisingly common. Many heirs gain access to a decedent's exchange account and simply begin trading without formally establishing their heir status. This means the exchange continues treating the account as belonging to the decedent, with the decedent's basis records. When sales occur, the 1099-DA reflects incorrect information tied to the decedent's social security number and basis.

 

Using the wrong valuation date can either cost money or trigger audit risk. The default basis for inherited property is fair market value on date of death. However, if the estate elected alternate valuation (six months later), that date determines basis instead. Heirs must coordinate with the estate executor to confirm which valuation date was elected and use the corresponding value consistently.

 

Some heirs make the opposite mistake of over-claiming stepped-up basis. Cryptocurrency received as a lifetime gift, rather than inheritance at death, does not qualify for step-up. Neither does crypto in certain types of trusts or crypto purchased by the decedent after the heir was identified as beneficiary in some circumstances. Incorrectly claiming stepped-up basis is tax fraud and can result in penalties and interest.

 

 

✅ The Heir's 1099-DA Compliance Checklist

 

Form 1099-DA compliance checklist cryptocurrency heirs tax filing requirements 2026

Figure 5: The comprehensive compliance checklist for crypto heirs navigating Form 1099-DA requirements. Following these steps systematically ensures accurate reporting, maximum tax efficiency, and protection against IRS inquiries.

 

Navigating Form 1099-DA as a crypto heir requires systematic attention to detail. The following checklist provides a comprehensive framework for compliance, organized by timing relative to inheritance and tax filing. Completing each step helps ensure accurate reporting and maximum tax efficiency while minimizing audit risk.

 

πŸ“‹ Immediate Actions (Upon Learning of Inheritance)

Action Priority Notes
Document FMV on date of death for all crypto Critical Screenshot exchange prices, record values
Obtain certified death certificate copies Critical Exchanges require certified copies
Inventory all decedent crypto holdings High Exchanges, wallets, DeFi positions
Secure access to decedent accounts High Work with executor for credentials
Confirm valuation date (DOD vs alternate) High Coordinate with estate executor

 

πŸ“‹ Transfer Phase Actions

Action Priority Notes
Complete exchange inheritance process Critical Submit required documentation
Establish heir account with stepped-up basis Critical Provide DOD values to exchange
Keep inherited crypto in separate account High Do not mix with purchased crypto
Transfer self-custody crypto with records High Document basis for each transfer
Verify exchange basis records match your records Medium Request confirmation from exchange

 

πŸ“‹ Tax Filing Phase Actions

Action Priority Notes
Collect all 1099-DA forms received Critical From every exchange used
Compare 1099-DA basis to your records Critical Identify discrepancies
Prepare Form 8949 with corrections if needed Critical Use column (f) for adjustments
Attach explanation for basis adjustments High Reference inheritance, IRC 1014
Retain all documentation for 7+ years High Death cert, valuations, estate docs

 

When your 1099-DA reports incorrect basis for inherited cryptocurrency, you must adjust on Form 8949. Report the 1099-DA information in columns (a) through (e), then use column (f) for adjustment code "B" (basis reported to IRS is incorrect) and column (g) to enter the adjustment amount. The result in column (h) should reflect your correct gain or loss using stepped-up basis.

 

Attach a statement to your return explaining the adjustment. A simple explanation such as "Basis adjusted to reflect stepped-up basis under IRC Section 1014 for cryptocurrency inherited from [Decedent Name] who died on [Date]. Fair market value on date of death was [Amount] per [Source]" provides sufficient context for IRS processing.

 

Consider engaging a tax professional experienced with cryptocurrency and estate matters. The intersection of 1099-DA reporting, inherited asset basis rules, and cryptocurrency taxation creates complexity that benefits from expert guidance. The cost of professional assistance is typically far less than the tax savings from proper basis reporting or the penalties from compliance errors.

 

✅ Ensure your 1099-DA compliance is complete!
Access official IRS resources.

 

❓ FAQ (30 Questions Answered)

 

Q1. What is IRS Form 1099-DA?

 

A1. Form 1099-DA is the IRS's new information reporting form for digital asset transactions. Beginning in 2025, cryptocurrency exchanges must use this form to report sales proceeds to both taxpayers and the IRS, with cost basis reporting added in 2026.

 

Q2. When did Form 1099-DA requirements take effect?

 

A2. Gross proceeds reporting began for tax year 2025 (forms issued January 2026). Cost basis reporting began January 1, 2026, meaning full basis information will appear on forms issued in January 2027 for 2026 transactions.

 

Q3. Does inherited cryptocurrency get a step-up in basis?

 

A3. Yes, under IRC Section 1014, inherited cryptocurrency receives a stepped-up basis equal to fair market value on the date of death (or alternate valuation date if elected). This eliminates all gains that accumulated during the decedent's lifetime.

 

Q4. Will my 1099-DA show the correct stepped-up basis for inherited crypto?

 

A4. Possibly not. Exchanges may not automatically know assets were inherited or what the stepped-up basis should be. You may need to correct the basis on your tax return using Form 8949, even if the 1099-DA shows different figures.

 

Q5. How do I correct an incorrect basis on my 1099-DA?

 

A5. Report the 1099-DA information on Form 8949, then use column (f) with adjustment code "B" and column (g) for the adjustment amount. Attach an explanation referencing IRC Section 1014 and the stepped-up basis for inherited property.

 

Q6. What documentation do I need to prove stepped-up basis?

 

A6. Key documents include certified death certificate, estate documentation showing you as heir, records of cryptocurrency values on date of death (exchange statements, price data), and any formal appraisals prepared for the estate.

 

Q7. Is inherited crypto automatically long-term for capital gains purposes?

 

A7. Yes, inherited property is automatically treated as long-term regardless of how long the decedent held it or how soon after inheritance you sell. This qualifies gains for preferential long-term capital gains rates (0%, 15%, or 20%).

 

Q8. What if my 1099-DA shows zero basis?

 

A8. Zero basis typically means the exchange doesn't have basis records. For inherited crypto, calculate your stepped-up basis (FMV at death) and report it on Form 8949 with an adjustment. Never accept zero basis if you have legitimate basis to claim.

 

Q9. Should I notify the exchange that I inherited the cryptocurrency?

 

A9. Yes, completing the exchange's inheritance transfer process ensures your account is properly established with correct basis records. This may prevent incorrect 1099-DA reporting for future sales.

 

Q10. What is the alternate valuation date and should I use it?

 

A10. The alternate valuation date is six months after death, elected by the estate. It may provide higher basis if crypto values declined after death. The decision is made by the executor for estate tax purposes, and heirs must use the same date for basis.

 

Q11. Can I mix inherited crypto with crypto I purchased myself?

 

A11. While legally possible, it creates basis tracking complications. Keeping inherited crypto in a separate wallet or account makes it easier to identify which assets have stepped-up basis versus your original purchase basis.

 

Q12. What cost basis methods are available under 1099-DA?

 

A12. Available methods include FIFO (first in, first out), LIFO (last in, first out), HIFO (highest in, first out), and specific identification. Specific identification offers the most flexibility for heirs to optimize tax outcomes.

 

Q13. Does crypto held in a hardware wallet receive a 1099-DA?

 

A13. No, self-custody wallets do not report to the IRS. A 1099-DA is only generated when you sell crypto through a broker (exchange). Heirs holding inherited crypto in self-custody must track basis independently.

 

Q14. What if the decedent's crypto was held on multiple exchanges?

 

A14. You may receive multiple 1099-DA forms. Complete the inheritance process with each exchange separately, establish stepped-up basis at each, and aggregate all forms when filing your tax return.

 

Q15. Is gifted crypto treated the same as inherited crypto for basis?

 

A15. No, gifted crypto receives carryover basis (the donor's original basis), not stepped-up basis. Only crypto transferred at death qualifies for step-up. This distinction can mean hundreds of thousands in tax differences.

 

Q16. How do I determine fair market value on date of death?

 

A16. Use the average of high and low prices on major exchanges for that date, or a single reputable exchange's price. For less liquid assets, professional appraisal may be needed. Document your methodology.

 

Q17. What if the decedent died on a weekend when markets were slow?

 

A17. Cryptocurrency markets trade 24/7/365, so values are available for any date. Use the price on the actual date of death, even if it falls on a weekend or holiday.

 

Q18. Are staking rewards earned after death also inherited?

 

A18. Staking rewards earned after death are income to the estate or heir, not inherited property. These rewards have basis equal to fair market value when received and do not qualify for step-up treatment.

 

Q19. What penalties apply if I ignore 1099-DA discrepancies?

 

A19. The IRS computers match 1099-DA reports against your return. Discrepancies trigger CP2000 notices assessing additional tax plus interest. If you disagree with the assessment, you must respond with documentation supporting your position.

 

Q20. Can the executor sell crypto before distributing to heirs?

 

A20. Yes, and this may be appropriate for paying estate debts or taxes. The estate reports the sale using stepped-up basis. However, distributing crypto in-kind to heirs preserves their ability to defer gains further.

 

Q21. How does 1099-DA interact with Form 8949?

 

A21. 1099-DA provides the information you report on Form 8949. You transcribe the data from 1099-DA to Form 8949, making any necessary basis adjustments, then carry totals to Schedule D of your Form 1040.

 

Q22. What if the exchange goes bankrupt before issuing my 1099-DA?

 

A22. You must still report your transactions based on your own records. Keep transaction histories, download statements regularly, and maintain independent records to protect against exchange failures.

 

Q23. Are DeFi transactions reported on 1099-DA?

 

A23. Not yet fully, though the IRS has indicated future guidance will address DeFi. Some front-ends may begin reporting. Currently, most pure DeFi transactions remain self-reported based on your own records.

 

Q24. How long should I keep 1099-DA records?

 

A24. Retain records for at least seven years after filing the return reporting the sale. For inherited crypto, keep documentation proving stepped-up basis indefinitely, as the IRS can question basis years later.

 

Q25. What if I inherited crypto from someone in another country?

 

A25. US tax treatment depends on your residency status, not the decedent's. US persons receiving inherited crypto from foreign decedents still qualify for stepped-up basis under IRC 1014, but additional reporting (Form 3520) may be required.

 

Q26. Does NFT inheritance work the same way as cryptocurrency?

 

A26. Yes, NFTs qualify for stepped-up basis at death under the same IRC Section 1014 rules. Valuation may be more complex for unique or illiquid NFTs, potentially requiring professional appraisal.

 

Q27. Can I amend prior returns if I overpaid due to wrong basis?

 

A27. Yes, file Form 1040-X to amend returns within three years of the original due date. If you used incorrect basis for inherited crypto and overpaid, amended returns can recover the overpayment plus interest.

 

Q28. What if the decedent never reported crypto on their tax returns?

 

A28. The heir still qualifies for stepped-up basis regardless of the decedent's compliance. However, the estate may have obligations to file final returns and address any unreported income or gains of the decedent.

 

Q29. Is there software to help track inherited crypto basis?

 

A29. Yes, crypto tax software like CoinTracker, Koinly, and TaxBit allow manual entry of inherited assets with custom basis. These tools can then track subsequent transactions and generate Form 8949 reports.

 

Q30. Should I hire a tax professional for inherited crypto?

 

A30. For significant inherited crypto holdings, professional guidance is highly recommended. The intersection of estate law, basis rules, and 1099-DA reporting creates complexity where errors are costly. Professional fees typically pale compared to potential tax savings or avoided penalties.

 

 

Official Government & Regulatory Resources

Verify information and stay compliant with authoritative sources

These links direct to official U.S. government websites for verification purposes.

 

⚖️ Legal and Financial Disclaimer

The information provided in this article is for educational and informational purposes only and does not constitute legal, tax, or financial advice. Tax laws change frequently, and individual circumstances vary significantly. Before making any tax decisions regarding inherited cryptocurrency or Form 1099-DA compliance, consult with qualified tax professionals and estate planning attorneys licensed in your jurisdiction. This content reflects regulations as of January 2026 and may not account for subsequent changes. The author and publisher disclaim any liability for actions taken based on this information.

πŸ–Ό️ Image Usage Notice

Some images in this article are AI-generated visualizations created to illustrate concepts discussed in the text. They are intended for educational purposes and may not represent actual IRS forms, documents, or specific tax scenarios. For official form images and instructions, please refer to IRS.gov.

 

 

1099-DA Crypto Tax Form 2026 — First Year Guide

1099-DA Crypto Tax Form 2026

✍️ Author Information

Written by: Davit Cho

Crypto Tax Specialist | CEO at JejuPanaTek (2012~) | Patent Holder (Patent #10-1998821)

7+ years crypto investing experience since 2017 | Personally filed crypto taxes since 2018

LinkedIn: linkedin.com/in/davit-cho-crypto

Email: davitchh@gmail.com

Blog: legalmoneytalk.blogspot.com

Last Updated: December 26, 2025 | Fact-Checked: Based on IRS Publications & Official Guidelines

 

2026 marks a major shift in how the IRS tracks cryptocurrency transactions. For the first time ever, crypto exchanges and brokers are required to send Form 1099-DA to both investors and the IRS — creating a paper trail that didn't exist before.

 

When I think about it, this is the biggest change to crypto tax reporting since the IRS first declared crypto as property in 2014. If you've been flying under the radar, those days are officially over. The IRS will now know exactly what you traded, when you traded it, and potentially how much you made.

 

This comprehensive guide covers everything you need to know about Form 1099-DA — what it is, who receives it, what information it contains, and how to use it correctly when filing your 2025 tax return in 2026.

 

πŸ“„ 1099-DA Quick Facts 2026

πŸ“… First Year Required: 2026 (for 2025 transactions)

πŸ“¬ Mailing Deadline: January 31, 2026

🏒 Who Sends: Exchanges, brokers, custodians

⚠️ DeFi/Self-Custody: NOT included (you must self-report)

 

πŸ“„ What Is Form 1099-DA?

 

Form 1099-DA (Digital Assets) is a brand new IRS tax form specifically designed for reporting cryptocurrency and digital asset transactions. It's the crypto equivalent of Form 1099-B that stock brokers have used for decades to report securities transactions.

 

The form was created as part of the Infrastructure Investment and Jobs Act of 2021, which expanded the definition of "broker" to include cryptocurrency exchanges. After years of delays and industry pushback, the IRS finalized the regulations in 2024, making 2026 the first year these forms will be issued.

 

Before 1099-DA, crypto exchanges issued Form 1099-K or 1099-MISC inconsistently, and often only reported gross proceeds — not the detailed transaction-by-transaction data the IRS wanted. Many exchanges issued nothing at all. This made it easy for crypto investors to underreport or completely ignore their tax obligations.

 

The new form changes everything. It requires brokers to report detailed information about each transaction, including proceeds, cost basis (when available), and gain or loss calculations. The IRS receives a copy, your state tax agency may receive a copy, and you receive a copy.

 

πŸ“„ 1099-DA vs Previous Forms

Form What It Reported Limitation
1099-K (old) Gross payment volume No cost basis, no gain/loss
1099-MISC (old) Staking/rewards income No transaction details
1099-DA (new) Each transaction with cost basis Centralized exchanges only

Source: IRS Notice 2024-56 | Infrastructure Investment and Jobs Act 2021

 

The goal is simple: make crypto tax reporting as standardized and unavoidable as stock trading. No more claiming you "didn't know" you owed taxes. No more hoping the IRS wouldn't notice your trades. The information is now automatically shared.

 

This represents a fundamental shift in how the IRS approaches crypto enforcement. Instead of relying on audits and investigations to catch tax evaders, they're building a system where compliance is the default because all the data is already in their hands.

 

For honest taxpayers who've been reporting correctly all along, this is actually good news — the form makes tax preparation easier. For those who haven't been reporting, it's time to get compliant before the IRS comes knocking.

 

πŸ“š Official IRS Resources

IRS guidance on digital asset reporting requirements.

πŸ“– IRS Digital Assets Guidance

πŸ“– About Form 1099-DA

 

πŸ‘€ Who Will Receive a 1099-DA?

 

Not everyone who owns crypto will receive a 1099-DA. The form is only issued by entities classified as "brokers" under the new IRS regulations. Understanding who does and doesn't send these forms is critical for proper tax reporting.

 

If you traded on a major centralized exchange like Coinbase, Kraken, Gemini, or Binance US during 2025, you will receive a 1099-DA in early 2026. These platforms are definitively classified as brokers and are required to report your transactions.

 

The threshold for receiving a form is any reportable transaction — there's no minimum dollar amount like the old 1099-K rules. Even if you made one small trade, you should expect to receive a form. If you only bought crypto and never sold, you typically won't receive a 1099-DA because purchases aren't taxable events.

 

Custodial wallet services that facilitate sales may also send 1099-DAs. If your wallet allows you to sell crypto directly for fiat currency, the company operating that wallet may be considered a broker.

 

πŸ‘€ Who Sends 1099-DA — and Who Doesn't

Platform Type Sends 1099-DA? Your Responsibility
Coinbase, Kraken, Gemini Yes Verify accuracy
Binance US, Crypto.com Yes Verify accuracy
Uniswap, SushiSwap (DEX) No Full self-reporting
MetaMask, Ledger (self-custody) No Full self-reporting
Foreign exchanges (Binance.com) No (for now) Full self-reporting
Peer-to-peer trades No Full self-reporting

Source: IRS Final Regulations on Digital Asset Broker Reporting 2024

 

Decentralized exchanges (DEXs) like Uniswap, SushiSwap, and PancakeSwap are currently NOT required to send 1099-DAs. The IRS tried to include them but faced legal and technical challenges. For now, DEX transactions must be self-reported — the IRS won't receive automatic notification of your trades.

 

Self-custody wallets like MetaMask, Ledger, or Trezor don't send 1099-DAs. These are just software or hardware that holds your keys — they don't facilitate trades. Any transactions you make from self-custody wallets must be tracked and reported by you.

 

Foreign exchanges present a gray area. Exchanges based outside the US may not be subject to 1099-DA requirements. However, US taxpayers are still legally required to report all income regardless of whether they receive a form. Using a foreign exchange doesn't make your gains tax-free.

 

The key takeaway: receiving a 1099-DA doesn't mean you're compliant, and NOT receiving one doesn't mean you're off the hook. You're responsible for reporting all taxable transactions regardless of what forms you receive.

 

⚠️ DeFi Users: You Must Self-Report

DEX trades, DeFi yields, and self-custody transactions won't appear on any 1099-DA. You're still legally required to report them.

πŸ“– Best Crypto Tax Software for DeFi Tracking

 

πŸ“Š What Information Is Reported?

 

Form 1099-DA contains detailed transaction-level information that gives the IRS a complete picture of your crypto trading activity. Understanding each field helps you verify accuracy and prepare for filing.

 

The form reports every disposal event — sales, trades, and exchanges — that occurred on the platform during the tax year. A disposal is any time you give up ownership of crypto, whether you sold it for cash, traded it for another cryptocurrency, or used it to buy goods or services.

 

For each transaction, the form includes the date of the transaction, the type and amount of cryptocurrency sold, the gross proceeds (fair market value at time of sale), and ideally the cost basis. The difference between proceeds and cost basis is your gain or loss.

 

Cost basis reporting is the trickiest part. Exchanges can only report cost basis for crypto you purchased directly on their platform. If you transferred crypto in from another exchange or wallet, they don't know what you originally paid for it. In these cases, the cost basis field may be blank or marked as "unknown."

 

πŸ“Š Key Fields on Form 1099-DA

Field Description Example
Box 1a: Digital Asset Description What you sold 0.5 BTC
Box 1b: Date Acquired When you bought it 03/15/2024
Box 1c: Date of Sale When you sold it 11/20/2025
Box 1d: Proceeds Sale price in USD $52,500
Box 1e: Cost Basis What you paid $35,000
Box 1g: Gain or Loss Proceeds minus cost basis $17,500

Source: IRS Form 1099-DA Draft Instructions 2024

 

The holding period determines whether your gain is short-term or long-term. If you held the crypto for one year or less, it's short-term (taxed at ordinary income rates up to 37%). If you held it longer than one year, it's long-term (taxed at preferential rates of 0%, 15%, or 20%).

 

Staking rewards, airdrops, and mining income may be reported on a separate section or a different form entirely. These are treated as ordinary income when received, not capital gains. The 1099-DA primarily focuses on capital transactions.

 

Transaction fees are important but handled inconsistently. In theory, fees should be added to your cost basis (when buying) or subtracted from proceeds (when selling), reducing your taxable gain. Make sure your form reflects this correctly.

 

Crypto-to-crypto trades are fully taxable and will be reported. If you traded 1 BTC for 15 ETH, that's a disposal of BTC. The "proceeds" is the fair market value of the ETH you received, and your gain is the difference between that value and your BTC cost basis.

 

Wash sales are NOT currently adjusted on 1099-DA. Unlike stocks, the wash sale rule doesn't apply to crypto yet, so you can harvest losses and immediately repurchase. If this changes in the future, the form may need to reflect disallowed losses.

 

πŸ’‘ No Wash Sale Rule for Crypto (Yet)

Unlike stocks, you can sell crypto at a loss and immediately rebuy without losing the deduction.

πŸ“– Crypto Wash Sale Rules 2026 — Full Guide

 

πŸ“… Timeline and Deadlines

 

Understanding the 1099-DA timeline helps you prepare for tax season and know when to expect your forms. Missing these dates or ignoring discrepancies can lead to IRS notices and penalties.

 

Brokers are required to mail 1099-DA forms to taxpayers by January 31, 2026. This is the same deadline as other 1099 forms. You should receive your form by mid-February at the latest. Many exchanges also provide electronic access through their platforms earlier than the mail date.

 

The IRS receives their copy of your 1099-DA by the same deadline. This means by the time you file your return, the IRS already knows about your transactions. If your return doesn't match what they have on file, it will trigger a notice.

 

Your tax return deadline is April 15, 2026 for most taxpayers. If you need more time, you can file for an extension until October 15, 2026 — but remember, an extension to file is not an extension to pay. You must estimate and pay any taxes owed by April 15 to avoid penalties and interest.

 

πŸ“… Key 2026 Tax Dates for Crypto Investors

Date Event Action Required
January 15, 2026 Q4 2025 estimated tax due Pay estimated taxes
January 31, 2026 1099-DA mailing deadline Watch for forms
February 15, 2026 Should have received all forms Contact exchanges if missing
April 15, 2026 Tax return due File or extend
October 15, 2026 Extended return due File if extended

Source: IRS Publication 509 | Tax Calendar for 2026

 

If you don't receive a 1099-DA by mid-February, log into your exchange accounts to check for electronic delivery. Many platforms now default to electronic forms. If you still can't find it, contact customer support — you may need to request a replacement.

 

Don't wait for your 1099-DA to start preparing. Most exchanges provide downloadable transaction history throughout the year. Use this data with crypto tax software to generate preliminary calculations before your official forms arrive.

 

If you receive a corrected 1099-DA after filing your return, you may need to amend. Exchanges sometimes issue corrections in February or March if they discover errors. Compare any corrected forms to your already-filed return and amend if the differences are material.

 

Keep your 1099-DA forms for at least seven years. The IRS can audit returns up to three years back (six years if there's substantial underreporting), and having the original forms is essential for defending your positions.

 

πŸ“… Full Q1 2026 Tax Calendar

All critical crypto tax deadlines in one place.

πŸ“– Q1 2026 Crypto Tax Calendar — All Deadlines

 

πŸ’‘ How to Use Your 1099-DA for Filing

 

Once you receive your 1099-DA, the next step is transferring that information to your tax return. The process is similar to reporting stock sales, using Form 8949 and Schedule D. Here's how to do it correctly.

 

First, verify your 1099-DA is accurate. Compare the transactions listed against your own records. Check that dates, amounts, and cost basis figures match what you expected. Exchanges make mistakes, especially with cost basis for transferred crypto.

 

If your 1099-DA shows "unknown" cost basis, you must calculate it yourself. Look back at your purchase records — when did you originally buy the crypto, and what did you pay? This is why keeping good records throughout the year is so important.

 

Report each transaction on Form 8949 (Sales and Other Dispositions of Capital Assets). You'll list the crypto type, date acquired, date sold, proceeds, cost basis, and gain or loss. The form has two sections: short-term (held one year or less) and long-term (held more than one year).

 

πŸ’‘ Step-by-Step Filing Process

Step Action Form
1 Receive and verify 1099-DA 1099-DA
2 Calculate missing cost basis Your records
3 List each transaction Form 8949
4 Summarize gains/losses Schedule D
5 Transfer to main return Form 1040

Source: IRS Form 8949 Instructions | Schedule D Instructions

 

After completing Form 8949, transfer the totals to Schedule D (Capital Gains and Losses). This form calculates your total capital gains or losses and determines how much tax you owe. The final figure then flows to your Form 1040 (main tax return).

 

If you have hundreds of transactions, you can summarize them rather than listing each one individually. Attach a statement with the transaction details and write "See attached statement" on Form 8949. Most crypto tax software generates this format automatically.

 

Use code "B" or "E" in Column (f) of Form 8949 to indicate the 1099-DA was received but cost basis was not reported to the IRS. This tells the IRS you're providing the cost basis yourself. Using the wrong code can trigger unnecessary notices.

 

Don't forget about crypto income that's NOT on Form 1099-DA. Staking rewards, mining income, airdrops, and payments received in crypto are taxed as ordinary income and reported elsewhere — typically Schedule 1 (Additional Income) or Schedule C (if it's a business).

 

Consider using crypto tax software like CoinTracker, Koinly, or TaxBit. These platforms import data directly from exchanges, calculate gains/losses, and generate IRS-ready forms. They're especially useful if you have multiple exchanges, DeFi transactions, or complex trading history.

 

πŸ’‘ Simplify Your Filing

Crypto tax software automates Form 8949 generation.

πŸ“– Best Crypto Tax Software 2026 Compared

 

⚠️ Common Issues and How to Fix Them

 

The first year of any new tax form comes with growing pains. Expect some issues with your 1099-DA. Knowing the common problems and how to resolve them prevents filing delays and IRS headaches.

 

Missing cost basis is the most common issue. If you transferred crypto to an exchange from an external wallet, the exchange doesn't know what you paid for it. Your 1099-DA may show proceeds but no cost basis — or worse, may assume zero cost basis, making your gains look much larger than they are.

 

The fix: Calculate cost basis yourself using your original purchase records. Report the correct cost basis on Form 8949 and be prepared to substantiate it if the IRS asks. Keep records of your original purchase confirmations, bank statements, or wallet transaction history.

 

Duplicate reporting can happen if you use multiple exchanges. If you transferred crypto from Exchange A to Exchange B, both might report the disposal. Make sure you're not accidentally reporting the same transaction twice.

 

⚠️ Common 1099-DA Problems and Solutions

Problem Cause Solution
Missing cost basis Transferred crypto in Calculate and report yourself
Incorrect proceeds Exchange calculation error Request corrected form
Duplicate transactions Multiple exchanges Reconcile and eliminate duplicates
Missing transactions Technical issues Add from your own records
Wrong holding period Transfer date used instead of purchase Correct on Form 8949
Form never received Mailing/email issue Check online, contact support

Document all discrepancies and corrections in case of IRS inquiry

 

Wrong holding period classification is another issue. If you transferred long-term holdings to a new exchange and then sold, the exchange may classify the sale as short-term because they only see when you deposited to their platform — not when you originally bought.

 

The fix: Override the holding period on Form 8949 using your actual purchase date. The IRS allows you to report the correct holding period even if the 1099-DA shows something different. Just make sure you have records to prove it.

 

Timing discrepancies between exchanges can cause confusion. If you sold crypto at 11:58 PM on December 31st on the East Coast, but the exchange runs on UTC time, it might show as January 1st. This could affect which tax year the transaction falls into.

 

If you believe your 1099-DA contains material errors, contact the exchange to request a corrected form. Exchanges are required to issue corrected 1099s when they become aware of errors. Document your communication in case you need to prove you tried to resolve the issue.

 

When in doubt, report what's correct — not what's on the form. If you have documentation supporting a different figure than what's on your 1099-DA, use your figures. Just be prepared to explain the discrepancy if the IRS asks.

 

⚠️ Avoid IRS Red Flags

Large discrepancies between your return and 1099-DA can trigger audits.

πŸ“– IRS Crypto Audit Red Flags 2026

 

 

❓ FAQ

 

Q1. When will I receive my 1099-DA?

 

A1. Exchanges must mail 1099-DA forms by January 31, 2026. You should receive yours by mid-February. Many exchanges also provide electronic access through their platforms, which may be available earlier. Check your exchange account settings to ensure your address and email are current.

 

Q2. What if I only bought crypto and never sold?

 

A2. You likely won't receive a 1099-DA. The form only reports disposals — sales, trades, or exchanges. Simply buying and holding crypto is not a taxable event. However, if you received staking rewards, airdrops, or other income, those may be reported on different forms.

 

Q3. Will DeFi transactions be on my 1099-DA?

 

A3. No. Decentralized exchanges (DEXs) and DeFi protocols are not currently required to issue 1099-DA forms. You must track and report these transactions yourself. Use crypto tax software or blockchain explorers to compile your DeFi transaction history.

 

Q4. What if my 1099-DA shows wrong cost basis?

 

A4. Report the correct cost basis on Form 8949. Use code "B" (short-term) or "E" (long-term) in Column (f) to indicate you're correcting the basis. Keep documentation of your actual purchase to support your figures if the IRS asks.

 

Q5. Do I need to report transactions not on the 1099-DA?

 

A5. Yes. You're legally required to report all taxable transactions regardless of whether you receive a form. DEX trades, peer-to-peer sales, and foreign exchange transactions must still be reported even though no 1099-DA is issued.

 

Q6. What if I used multiple exchanges?

 

A6. You'll receive a separate 1099-DA from each exchange where you had taxable transactions. Compile all forms when preparing your return. Watch for duplicate reporting if you transferred crypto between exchanges — the transfer itself isn't taxable, but both exchanges might report related transactions.

 

Q7. Are NFT sales reported on 1099-DA?

 

A7. It depends on the platform. Centralized NFT marketplaces that act as brokers may issue 1099-DAs for sales. However, many NFT transactions occur through smart contracts without a traditional broker, meaning no form will be issued. NFT gains are still taxable and may face the 28% collectibles rate.

 

Q8. What happens if I ignore my 1099-DA?

 

A8. The IRS receives a copy of your 1099-DA. If your tax return doesn't include the reported transactions, their automated matching system will flag the discrepancy. You'll receive a CP2000 notice proposing additional tax. Continued non-compliance can lead to penalties, interest, and potential audit.

 

⚠️ Disclaimer

This article is for informational purposes only and does not constitute tax, legal, or financial advice. Form 1099-DA requirements are new and may be subject to additional IRS guidance. Tax treatment may vary based on specific facts and individual circumstances.

Consult with a qualified CPA, tax attorney, or other licensed professional before making any tax-related decisions. The author and publisher are not responsible for any errors, omissions, or actions taken based on this information.

Sources: Infrastructure Investment and Jobs Act 2021 | IRS Notice 2024-56 | IRS Form 1099-DA Instructions | IRS Publication 550

Last Updated: December 26, 2025 | Author: Davit Cho | LinkedIn: linkedin.com/in/davit-cho-crypto

 

Tags: 1099-DA, Crypto Tax Form, IRS Crypto Reporting, Digital Asset Tax, Crypto Tax 2026, Form 8949, Schedule D, Cryptocurrency Tax, Tax Filing, Broker Reporting

DeFi Users Beware: IRS Form 8949 Mismatch = Automatic Audit in 2026

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