Morgan Stanley Bitcoin ETF 2026 — Wall Street's $62B Signal

💡 Key Takeaways (30-Sec Summary)

✅ Morgan Stanley filed S-1 for Bitcoin, Ethereum, and Solana ETFs on January 6, 2026 — the last major Wall Street bank to enter

✅ BlackRock IBIT cumulative inflows hit $62.98B — January 2026 started with $1.5B inflows, then saw $1.1B outflows in 3 days

✅ Institutional adoption is now irreversible — the question is not "if" but "how much" to allocate

On January 6, 2026, Morgan Stanley Investment Management filed S-1 registration statements with the SEC for three cryptocurrency exchange-traded products. This was not just another ETF filing. This was the last major Wall Street institution acknowledging that Bitcoin has become a permanent asset class.

 

For years, traditional finance dismissed cryptocurrency as speculation. Now BlackRock manages $62.98 billion in Bitcoin through IBIT alone. Fidelity, Invesco, and Grayscale compete for the remaining market share. The institutional floodgates opened in January 2024, and two years later, Morgan Stanley's entry signals the end of Wall Street's crypto skepticism.

 

But here is the critical question: January 2026 also saw $1.1 billion in ETF outflows over three consecutive days. Is this profit-taking within a bull market, or the beginning of institutional rotation? This analysis breaks down what Morgan Stanley's filing means, why ETF flow data matters more than price, and how to position your portfolio for the next phase.

 

In my view, this moment represents the institutionalization inflection point that separates early adopters from latecomers. The data tells a clear story for those who know how to read it.

🏆 100% Ad-Free Experience — This analysis is supported by our readers. No sponsored content. No hidden agendas. Just institutional-grade research for serious investors.

Figure 1: Morgan Stanley's January 6, 2026 SEC filing marks the completion of Wall Street's Bitcoin adoption cycle. The S-1 registration for Bitcoin, Ethereum, and Solana ETFs positions the bank to compete directly with BlackRock and Fidelity in the institutional crypto custody race.

📋 Strategic Blueprint

• 1️⃣ Morgan Stanley S-1 Filing: What the Documents Reveal
• 2️⃣ Bitcoin ETF Landscape: $62B and Counting
• 3️⃣ January 2026 Flow Analysis: $1.5B In, $1.1B Out
• 4️⃣ ETF Comparison: IBIT vs FBTC vs GBTC
• 5️⃣ Institutional Adoption Signals for 2026
• 6️⃣ Portfolio Allocation Strategy
• 7️⃣ FAQ — 10 Critical Questions Answered

✍️ Author: Davit Cho, Global Asset Strategist & Crypto Law Expert

📋 Verification: SEC EDGAR Filings, Morgan Stanley Press Release, Bloomberg ETF Data

📅 Published: January 13, 2026

📧 Contact: davitchh@proton.me

1️⃣ Morgan Stanley S-1 Filing: What the Documents Reveal

Morgan Stanley Investment Management filed three separate S-1 registration statements with the Securities and Exchange Commission on January 6, 2026. The filings cover the Morgan Stanley Bitcoin Trust, Morgan Stanley Ethereum Trust, and Morgan Stanley Solana Trust. Each product is structured as a passive investment vehicle designed to track the spot price of its underlying cryptocurrency.

 

The timing is significant. Morgan Stanley was notably absent from the January 2024 spot Bitcoin ETF launch that included BlackRock, Fidelity, Invesco, and others. The bank's wealth management division had previously restricted Bitcoin ETF access to clients with at least $1.5 million in assets. Now, the firm is positioning itself to offer direct exposure through its own products.

 

The Solana filing is particularly noteworthy. While Bitcoin and Ethereum ETFs have established regulatory precedent, Solana represents a more aggressive bet on altcoin adoption. Morgan Stanley is signaling confidence that the SEC's commodity classification framework will extend beyond the two largest cryptocurrencies.

 

According to the SEC filings, the trusts will hold cryptocurrency directly rather than through derivatives. This structure mirrors the existing spot ETF framework and ensures that institutional buyers receive exposure to actual underlying assets rather than synthetic instruments.

📊 Morgan Stanley Filing Details

Product	Filing Date	Structure	SEC Registration
Morgan Stanley Bitcoin Trust	Jan 6, 2026	Spot ETF	S-1 Pending
Morgan Stanley Ethereum Trust	Jan 8, 2026	Spot ETF	S-1 Pending
Morgan Stanley Solana Trust	Jan 6, 2026	Spot ETF	S-1 Pending

 

The strategic implications extend beyond asset management. Morgan Stanley manages approximately $1.5 trillion in client assets through its wealth management division. Even a 1% allocation recommendation would translate to $15 billion in potential Bitcoin demand. The firm's entry validates cryptocurrency as a core portfolio component rather than a speculative sideshow.

 

Industry analysts expect SEC approval within 90 to 120 days, assuming no material deficiencies in the registration statements. The approval timeline places potential launch in Q2 2026, coinciding with increased institutional interest ahead of the U.S. midterm elections.

🏛️ How Trump's Bitcoin Reserve Impacts ETF Flows →

📋 SEC EDGAR: Morgan Stanley Filings →

2️⃣ Bitcoin ETF Landscape: $62B and Counting

The U.S. spot Bitcoin ETF market has accumulated over $62 billion in assets under management since the January 2024 approval. BlackRock's iShares Bitcoin Trust dominates with $62.98 billion in cumulative net inflows, making it one of the most successful ETF launches in financial history. The product achieved this milestone in under two years.

 

Fidelity's FBTC holds the second position with approximately $12.5 billion in assets. The Grayscale Bitcoin Trust, which converted from a closed-end fund to an ETF, has experienced consistent outflows as investors rotate into lower-fee alternatives. GBTC's management fee of 1.5% compares unfavorably to IBIT's 0.25% and FBTC's 0.25%.

 

The competitive landscape has forced fee compression across the industry. New entrants must compete on cost, distribution, and brand recognition. Morgan Stanley's entry introduces a new dynamic: the wealth management channel. Unlike BlackRock and Fidelity, which primarily serve institutional clients through asset management divisions, Morgan Stanley's 15,000 financial advisors provide direct access to high-net-worth retail investors.

 

Figure 2: January 2026 ETF flow data reveals institutional sentiment shifts. The pattern of strong initial inflows followed by profit-taking outflows suggests tactical positioning rather than structural selling. BlackRock IBIT maintained positive flows even during the broader outflow period.

The total addressable market for Bitcoin ETFs continues to expand. Pension funds, endowments, and sovereign wealth funds are gradually adding cryptocurrency exposure through regulated vehicles. The ETF wrapper eliminates custody complexity, regulatory uncertainty, and operational risk that previously deterred institutional participation.

📊 Bitcoin ETF Market Share (January 2026)

ETF Ticker	Issuer	Cumulative Inflows	Expense Ratio
IBIT	BlackRock	$62.98B	0.25%
FBTC	Fidelity	$12.5B	0.25%
GBTC	Grayscale	-$21.3B	1.50%
ARKB	ARK/21Shares	$2.8B	0.21%

 

Goldman Sachs recently named Bitcoin-related equities as a top 2026 investment theme, citing the convergence of regulatory clarity, institutional adoption, and monetary policy uncertainty. The bank's research note specifically highlighted Coinbase as a primary beneficiary of increased ETF trading volume.

📉 Bitcoin $90K Correction Analysis — Buy or Sell? →

📊 BlackRock IBIT Official Product Page →

3️⃣ January 2026 Flow Analysis: $1.5B In, $1.1B Out

The first two trading days of 2026 saw extraordinary Bitcoin ETF inflows. January 2 recorded $473 million in net inflows, followed by $695 million on January 5. BlackRock's IBIT alone captured $371.9 million on January 5, with Fidelity's FBTC adding $208.2 million. Investors appeared eager to establish positions at the start of the new year.

 

The momentum reversed abruptly. January 7 through January 10 saw three consecutive days of outflows totaling $1.1 billion. Fidelity FBTC led the exodus with $312.24 million in single-day redemptions. Grayscale GBTC continued its chronic outflow pattern, losing $83.07 million. Only BlackRock IBIT maintained positive flows during this period, adding $228.66 million against the broader trend.

 

The divergence between IBIT and other ETFs reveals institutional preference. BlackRock's product has become the default choice for large allocators due to liquidity depth, brand trust, and operational infrastructure. Smaller ETFs face redemption pressure during risk-off periods while IBIT captures flight-to-quality flows within the Bitcoin ETF category.

 

📌 Market Reality Check

The January outflow pattern correlates with Bitcoin's price decline from $97,000 to $91,000 during the same period. On January 12, BlackRock alone accounted for nearly three-quarters of total ETF outflows. This concentration suggests that institutional repositioning, rather than retail panic selling, drove the redemptions. Professional investors are taking profits after Bitcoin's 120% gain in 2024.

📊 January 2026 Daily ETF Flows

Date	Net Flow	IBIT	FBTC	BTC Price
Jan 2	+$473M	+$298M	+$126M	$96,500
Jan 5	+$695M	+$371M	+$208M	$97,200
Jan 7	-$243M	+$229M	-$312M	$94,800
Jan 8-10	-$681M	-$193M	-$287M	$91,000

 

XRP ETFs provided a contrasting signal during this period. The Block reported that XRP ETFs hit record weekly volume as Bitcoin and Ethereum funds faced $750 million in combined outflows. This rotation suggests that institutional investors are diversifying crypto exposure rather than exiting the asset class entirely.

⚖️ XRP SEC Settlement — Why ETF Flows Are Shifting →

📈 Farside Investors: Real-Time ETF Flow Tracker →

4️⃣ ETF Comparison: IBIT vs FBTC vs GBTC

Choosing the right Bitcoin ETF requires understanding structural differences beyond expense ratios. BlackRock's IBIT offers the deepest liquidity with average daily trading volume exceeding $2 billion. This liquidity advantage reduces slippage costs for large orders and ensures tight bid-ask spreads during volatile periods.

 

Fidelity's FBTC provides direct custody through Fidelity Digital Assets, the firm's institutional-grade cryptocurrency custody platform. Some investors prefer Fidelity's vertically integrated model over BlackRock's third-party custody arrangement with Coinbase. The custody question becomes critical when considering counterparty risk in a market that lacks FDIC insurance.

 

Figure 3: The ETF comparison reveals that expense ratio alone does not determine total cost of ownership. Liquidity, custody model, and tracking error all impact long-term returns. IBIT's dominance stems from its superior liquidity profile rather than fee advantage.

Grayscale's GBTC remains relevant for specific use cases despite its chronic outflows. The fund's higher fee structure reflects its legacy as the first institutional Bitcoin investment vehicle. Tax-loss harvesting opportunities exist for investors who purchased GBTC at premium valuations before the ETF conversion.

 

📊 Complete ETF Comparison Matrix

Feature	IBIT	FBTC	GBTC
Expense Ratio	0.25%	0.25%	1.50%
Custodian	Coinbase	Fidelity Digital	Coinbase
Daily Volume	$2.1B avg	$890M avg	$420M avg
Tracking Error	0.02%	0.03%	0.08%
Bid-Ask Spread	0.01%	0.02%	0.04%

 

Morgan Stanley's entry will add another competitive dimension. The firm's captive distribution network provides access to clients who may not independently research cryptocurrency investment options. Financial advisors influence allocation decisions for trillions in managed assets.

💰 Staking vs ETF — Which Earns More After Taxes? →

🏦 Fidelity FBTC Official Product Page →

5️⃣ Institutional Adoption Signals for 2026

Morgan Stanley's filing represents the final domino in Wall Street's Bitcoin adoption sequence. Goldman Sachs, JPMorgan, and Bank of America all offer Bitcoin ETF access to clients through brokerage platforms. The question has shifted from whether institutions will adopt Bitcoin to how much they will allocate.

 

State pension funds provide a leading indicator of institutional sentiment. Wisconsin's State Investment Board disclosed a $160 million Bitcoin ETF position in 2024. Florida's State Board of Administration followed with exploratory allocations. These public pension commitments signal that fiduciary standards now accommodate cryptocurrency exposure.

 

Figure 4: Wall Street's transformation from crypto skeptic to crypto provider took less than three years. The shift reflects both regulatory clarity and client demand. Institutions that resisted adoption now risk losing assets to competitors who embrace digital asset offerings.

Corporate treasury adoption continues to expand beyond MicroStrategy's pioneering position. The company now holds over 446,000 BTC valued at approximately $40 billion. Smaller public companies have followed the playbook, using Bitcoin as a treasury reserve asset to hedge dollar depreciation and attract crypto-native investors.

 

📊 Institutional Adoption Milestones

Institution Type	Example	BTC Exposure	Vehicle
Asset Manager	BlackRock	$62.98B AUM	IBIT ETF
Public Company	MicroStrategy	446,000 BTC	Direct Custody
State Pension	Wisconsin SWIB	$160M	IBIT/GBTC
Wealth Manager	Morgan Stanley	TBD	Own ETF (Pending)

 

Trump's Strategic Bitcoin Reserve executive order adds a sovereign dimension to institutional adoption. The U.S. government now holds approximately 200,000 BTC valued at $18 billion. This policy shift eliminates the scenario where government sales create downward price pressure, removing a key risk factor for institutional allocators.

🏛️ January 15 Market Structure Vote — What Passes? →

📊 SIFMA: Official ETF Industry Statistics →

6️⃣ Portfolio Allocation Strategy

The optimal Bitcoin allocation depends on risk tolerance, investment horizon, and existing portfolio composition. Conservative institutional frameworks suggest 1% to 3% allocation for diversification benefits without material drawdown risk. More aggressive models target 5% to 10% for portfolios with higher volatility tolerance.

 

Dollar-cost averaging provides a systematic approach during periods of price uncertainty. The current $91,000 level sits between the January high of $97,000 and analyst support zones around $85,000. Spreading purchases across multiple weeks reduces timing risk and emotional decision-making.

 

Figure 5: Portfolio allocation models increasingly incorporate Bitcoin as a non-correlated asset class. The optimal percentage depends on individual risk tolerance and investment goals. Most institutional frameworks now recommend 1-5% exposure as baseline diversification.

ETF selection should match investment strategy. Long-term holders benefit from IBIT or FBTC's low expense ratios. Active traders may prefer GBTC's options market liquidity despite higher fees. Tax-advantaged accounts like IRAs eliminate capital gains concerns but require careful custodian selection.

 

📊 Allocation Framework by Risk Profile

Risk Profile	BTC Allocation	Recommended ETF	Rebalance Frequency
Conservative	1-2%	IBIT	Quarterly
Moderate	3-5%	IBIT/FBTC Split	Monthly
Aggressive	5-10%	IBIT + Direct BTC	Weekly Review
Crypto-Native	10-25%	Self-Custody + ETF	Active Management

 

Tax efficiency requires strategic planning. Bitcoin ETF gains qualify for long-term capital gains treatment after one year holding. Wash sale rules do not currently apply to cryptocurrency, creating tax-loss harvesting opportunities during corrections. The upcoming Form 1099-DA reporting requirements make accurate record-keeping essential.

📋 Form 1099-DA Penalty Relief — What You Must Know →

🏛️ IRS Official: Digital Asset Tax Guidance →

7️⃣ FAQ — 10 Critical Questions Answered

Q1. When will Morgan Stanley's Bitcoin ETF launch?

 

A1. SEC review typically takes 90 to 120 days from S-1 filing. Based on the January 6, 2026 filing date, approval could come as early as April 2026. The actual launch date depends on SEC comment resolution and market maker readiness.

 

Q2. Why did Bitcoin ETFs see $1.1 billion in outflows after strong January inflows?

 

A2. Institutional profit-taking drove the outflows. Bitcoin rose 120% in 2024, prompting year-end rebalancing and tax-motivated selling. The pattern reflects tactical repositioning rather than fundamental concern about Bitcoin's long-term value.

 

Q3. Should I buy IBIT, FBTC, or wait for Morgan Stanley's ETF?

 

A3. IBIT offers the deepest liquidity and tightest spreads. Waiting for Morgan Stanley's ETF only makes sense if you specifically want to use their wealth management platform. The underlying Bitcoin exposure is identical across products.

 

Q4. How much should I allocate to Bitcoin ETFs in 2026?

 

A4. Most institutional frameworks recommend 1% to 5% depending on risk tolerance. Conservative investors should start with 1% to 2% and evaluate performance over six months before increasing allocation.

 

Q5. What is BlackRock IBIT's total AUM?

 

A5. BlackRock's iShares Bitcoin Trust has accumulated $62.98 billion in cumulative net inflows since its January 2024 launch. This makes IBIT one of the most successful ETF launches in financial history.

 

Q6. Will Morgan Stanley's ETF have lower fees than IBIT?

 

A6. Fee details are not yet disclosed in the S-1 filing. Competitive pressure suggests Morgan Stanley will match or undercut the 0.25% expense ratio offered by IBIT and FBTC. Initial promotional fee waivers are likely.

 

Q7. Why is Morgan Stanley also filing for a Solana ETF?

 

A7. Solana represents a bet on altcoin ETF expansion. The filing signals confidence that the SEC's commodity classification will extend beyond Bitcoin and Ethereum. If approved, Morgan Stanley would be among the first traditional banks to offer Solana exposure.

 

Q8. How do Bitcoin ETF taxes work?

 

A8. Bitcoin ETF gains are taxed as capital gains. Holdings over one year qualify for long-term rates of 0%, 15%, or 20% depending on income. Short-term gains are taxed as ordinary income. ETFs issue Form 1099-B for reporting.

 

Q9. Is the January outflow a bearish signal?

 

A9. Short-term outflows during price corrections are normal. The critical indicator is BlackRock IBIT maintaining positive flows even during the broader outflow period. Institutional commitment remains strong despite tactical repositioning.

 

Q10. What price does Bitcoin need to reach for ETF flows to turn positive again?

 

A10. Historically, sustained price stability above key moving averages triggers institutional buying. A close above $95,000 would likely signal renewed inflow momentum. Current support zones around $88,000 to $90,000 represent potential accumulation levels.

📅 Q1 2026 Crypto Tax Calendar — Key Deadlines →

📋 SEC EDGAR: All Bitcoin ETF Filings →

📚 Official Resources

• 📋 SEC EDGAR: Morgan Stanley Bitcoin Trust S-1 Filing
• 🏦 Morgan Stanley: Official Press Release
• 📰 Reuters: Morgan Stanley Files for Bitcoin, Solana ETFs
• 📊 BlackRock: iShares Bitcoin Trust (IBIT) Product Page
• 🏛️ IRS: Digital Assets Tax Information

⚠️ Disclaimer

This article is for informational purposes only and does not constitute investment, tax, or legal advice. Cryptocurrency investments involve significant risk, including the potential loss of principal. Past performance does not guarantee future results. Consult a qualified financial advisor before making investment decisions. The author may hold positions in assets mentioned. All data is believed accurate as of publication date but is not guaranteed.

Image Usage: All images are original creations for editorial purposes. No endorsement by Morgan Stanley, BlackRock, Fidelity, or any other entity is implied.

✍️ Author: Davit Cho, Global Asset Strategist & Crypto Law Expert

📋 Verification: S.1582 GENIUS Act, FIT21, Senate Banking Committee Schedule

📅 Published: January 11, 2026

📧 Contact: davitchh@proton.me

Crypto Market Structure Bill 2026 — January 15 Senate Showdown

In 4 days, two Senate committees will hold synchronized markups on the most consequential crypto legislation in history. SEC vs CFTC jurisdiction hangs in the balance.

Figure 1: The January 15, 2026 Senate markup represents the culmination of years of regulatory uncertainty—finally determining whether crypto assets fall under SEC or CFTC jurisdiction, reshaping the entire industry's compliance landscape.

💡 Key Takeaways (30-Sec Summary)

• January 15 Markup: Senate Banking and Agriculture committees hold synchronized hearings on crypto market structure.
• SEC vs CFTC: Bill determines which regulator controls Bitcoin, Ethereum, and thousands of altcoins.
• Midterm Pressure: Industry pushing for passage before November 2026 elections risk unseating crypto-friendly lawmakers.

For seven years, the crypto industry has operated in regulatory purgatory. The SEC claims most tokens are securities. The CFTC says Bitcoin and possibly Ethereum are commodities. Courts have issued conflicting rulings. And investors have been left guessing which rules apply to their holdings.

 

That confusion could end on January 15, 2026. Two Senate committees—Banking and Agriculture—will hold synchronized markups on comprehensive market structure legislation. The bill aims to draw clear jurisdictional lines between the SEC and CFTC, establish registration pathways for crypto exchanges, and create the first federal framework for digital asset classification.

 

The stakes couldn't be higher. Crypto proponents want passage before the November 2026 midterms, fearing that election losses could unseat industry-friendly lawmakers and kill the bill entirely. Democrats are demanding stronger illicit finance provisions. DeFi advocates threaten to walk away if decentralized protocols face impossible compliance burdens.

 

This article breaks down exactly what's in the draft legislation, how SEC and CFTC jurisdiction would be divided, the DeFi carve-out controversy, and most critically—how different outcomes would impact your portfolio and tax obligations.

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📋 Strategic Blueprint

• 🏛️ 1. January 15 Markup — What's Actually Happening
• ⚖️ 2. SEC vs CFTC — The Jurisdiction Battle Explained
• 📜 3. What's In the Draft Bill — Key Provisions
• 🌐 4. The DeFi Carve-Out Controversy
• 📅 5. Legislative Timeline — Path to Passage
• 💼 6. Portfolio Impact — Scenarios and Positioning
• ❓ 7. FAQ — 10 Critical Questions Answered

🏛️ 1. January 15 Markup — What's Actually Happening

On January 15, 2026, the Senate Banking Committee and Senate Agriculture Committee will hold simultaneous markups on crypto market structure legislation. This synchronized approach is unusual—and intentional. Both committees claim partial jurisdiction over crypto, and coordinated action prevents turf wars that could derail the bill.

 

A "markup" is the legislative process where committee members review, debate, and amend draft legislation line by line. It's the critical step between introducing a bill and bringing it to the full Senate floor. What emerges from January 15 will shape the final legislation that could become law.

 

The Banking Committee, chaired by Senator Tim Scott (R-SC), oversees the SEC and securities regulation. The Agriculture Committee, chaired by Senator John Boozman (R-AR), oversees the CFTC and commodities regulation. Their cooperation signals genuine momentum—but also highlights the fundamental tension the bill must resolve: which regulator controls crypto?

 

Industry lobbyists have been working overtime. According to CNBC reporting from today, crypto proponents want passage before the November 2026 midterm elections. The fear is real: if crypto-friendly lawmakers lose seats, the window for favorable legislation could close for years. This political pressure is accelerating timelines that would normally stretch across multiple congressional sessions.

Committee	Chair	Jurisdiction	Key Focus
Senate Banking	Tim Scott (R-SC)	SEC, Securities	Token classification, exchange registration
Senate Agriculture	John Boozman (R-AR)	CFTC, Commodities	Bitcoin/ETH status, derivatives

⚖️ How SEC vs Ripple Shaped This Moment →

🏛️ Congress.gov: GENIUS Act Full Text →

⚖️ 2. SEC vs CFTC — The Jurisdiction Battle Explained

Figure 2: The jurisdictional divide between SEC (securities) and CFTC (commodities) has created years of regulatory confusion. The market structure bill aims to establish clear classification criteria for the first time.

The core question the bill must answer: Is a crypto token a security (SEC jurisdiction) or a commodity (CFTC jurisdiction)? This distinction determines everything—registration requirements, investor protections, tax treatment, and compliance costs.

 

The SEC has historically applied the Howey Test, a 1946 Supreme Court standard for identifying investment contracts. Under this framework, most token sales—where investors buy hoping for profit from the efforts of a development team—qualify as securities. Former SEC Chair Gary Gensler famously said "everything other than Bitcoin" is likely a security.

 

The CFTC takes a narrower view. It has consistently classified Bitcoin as a commodity—digital gold, essentially. The agency has also suggested Ethereum may be a commodity, particularly after its transition to proof-of-stake. Commodities face lighter regulation: no registration requirements for spot trading, though derivatives fall under CFTC oversight.

 

The draft market structure bill attempts to resolve this by creating a classification framework. Tokens would be evaluated based on decentralization metrics: if a network is "sufficiently decentralized"—meaning no single entity controls it—the underlying token would be classified as a commodity. Tokens from centralized projects would remain securities until they achieve decentralization.

📌 Market Reality Check

In my view, this jurisdictional clarity is the single most important development for crypto markets since the Bitcoin ETF approval. The current ambiguity has cost the industry billions in legal fees, killed promising projects, and driven innovation offshore. A clear framework—even an imperfect one—would unleash institutional capital that's been waiting on the sidelines for regulatory certainty.

Regulator	Classification	Requirements	Assets Covered
SEC	Security	Registration, disclosure, investor accreditation	Most altcoins, ICO tokens
CFTC	Commodity	Derivatives oversight, anti-fraud	Bitcoin, potentially Ethereum
Proposed: Hybrid	Decentralization-based	Transition pathway from security to commodity	Tokens meeting decentralization criteria

🏛️ How Government BTC Reserve Changes Everything →

📜 3. What's In the Draft Bill — Key Provisions

The market structure bill builds on the foundation laid by FIT21 (Financial Innovation and Technology for the 21st Century Act), which passed the House in 2024 but stalled in the Senate. The current draft incorporates lessons from that effort while addressing Democratic concerns about consumer protection and illicit finance.

 

The bill establishes a registration pathway for crypto exchanges. Platforms would register with either the SEC or CFTC depending on which assets they list. Dual registration would be required for platforms offering both securities and commodities—creating compliance burdens but also legal clarity that doesn't exist today.

 

Consumer protection provisions include mandatory custody requirements, proof-of-reserves disclosures, and segregation of customer assets. These rules directly respond to the FTX collapse, where customer funds were commingled with proprietary trading and ultimately lost. Exchanges would face regular audits and capital requirements.

 

The illicit finance section—reportedly being added to satisfy Democratic demands—would enhance Bank Secrecy Act compliance, require transaction monitoring, and potentially extend reporting requirements to certain DeFi protocols. This section remains contentious and could change significantly during markup.

Provision	Description	Impact
Decentralization Framework	Metrics for classifying tokens as commodities	Pathway for tokens to escape SEC oversight
Exchange Registration	SEC/CFTC registration based on listed assets	Legal clarity for Coinbase, Kraken, etc.
Custody Requirements	Segregation, proof-of-reserves, audits	FTX-style collapses prevented
Illicit Finance (Pending)	Enhanced BSA compliance, monitoring	Privacy concerns for DeFi users

📉 Bitcoin at $90K — How Legislation Affects Price →

🌐 4. The DeFi Carve-Out Controversy

Figure 3: DeFi protocols face an existential question under the market structure bill: can truly decentralized code be regulated like traditional financial institutions? The answer will determine whether $100B+ in DeFi value stays onshore or migrates overseas.

The most contentious issue in the market structure bill isn't SEC vs CFTC—it's DeFi. Decentralized finance protocols operate without central operators, making traditional registration requirements potentially impossible to satisfy. Who registers Uniswap when no company controls it?

 

According to CoinDesk reporting, the crypto industry could "walk away" from the bill entirely if DeFi needs aren't met. Industry advocates argue that truly decentralized protocols are software, not financial institutions. Requiring registration would be like requiring TCP/IP to register as a telecommunications carrier.

 

The draft bill attempts to address this through a "DeFi carve-out"—exemptions for protocols meeting strict decentralization criteria. But the details matter enormously. If the threshold is too high, no protocol qualifies. If too low, bad actors claim exemptions while operating centralized systems in disguise.

 

Democrats have resisted broad DeFi exemptions, citing illicit finance concerns. They point to hacks, rug pulls, and sanctions evasion facilitated through decentralized exchanges. The compromise being negotiated would exempt protocol-level software while potentially requiring front-end interfaces (like the Uniswap website) to implement some compliance measures.

DeFi Component	Proposed Treatment	Industry Position
Smart Contracts (Code)	Exempt if truly decentralized	Support
Front-End Interfaces	May require compliance measures	Conditional support
DAO Governance	Classification uncertain	Seeking clarity
Liquidity Providers	Not treated as brokers	Critical requirement

🌾 DeFi Tax Implications You Must Know →

📅 5. Legislative Timeline — Path to Passage

Figure 4: The legislative pathway from January markup through potential summer passage—with the November 2026 midterm elections creating an urgent deadline for crypto advocates fearing loss of congressional allies.

The January 15 markup is the starting gun, not the finish line. Here's the realistic pathway to passage—and the obstacles that could derail the bill at each stage.

 

After committee markup, the amended bill must pass both the Senate Banking and Agriculture committees. This requires majority votes in each. Given Republican control, passage is likely—but amendments could alter the bill significantly. Watch for changes to DeFi provisions and illicit finance requirements.

 

From there, the bill moves to the full Senate floor. This is where things get complicated. The filibuster means 60 votes are needed to advance most legislation. Republicans hold 53 seats; they need at least 7 Democrats. The illicit finance provisions are designed to attract Democratic support, but progressives like Elizabeth Warren remain skeptical of any crypto-friendly legislation.

 

If the Senate passes a bill, it must be reconciled with any House version. The House passed FIT21 in 2024, but the new Congress may want its own mark. Conference committee negotiations could stretch for months. Industry insiders are targeting Q2-Q3 2026 for final passage—before election season consumes congressional attention.

Date	Event	Significance
July 2025	GENIUS Act Signed	Stablecoin framework established
Jan 15, 2026	Senate Markup	Market structure bill formally debated
Q1 2026	Committee Votes	Bill advances to full Senate
Q2-Q3 2026	Floor Vote + Reconciliation	Final passage window
Nov 2026	Midterm Elections	Deadline—new Congress could kill bill

📄 Tax Reporting Changes Already Live — 1099-DA →

💼 6. Portfolio Impact — Scenarios and Positioning

Figure 5: Portfolio positioning for the three most likely legislative outcomes—from bullish passage to bearish collapse—with specific asset allocation implications for each scenario.

How should investors position for the January 15 markup and subsequent legislative process? The answer depends on which scenario unfolds—and each has distinct portfolio implications.

 

Scenario A: Bill Passes with Strong DeFi Protections. This is the bull case. Clear SEC/CFTC jurisdiction lines would unlock institutional capital that's been waiting for regulatory clarity. Tokens classified as commodities would see immediate relief rallies. DeFi protocols with strong decentralization credentials would benefit most. Expect ETH and major DeFi tokens (UNI, AAVE, MKR) to outperform.

 

Scenario B: Bill Passes with Restrictive DeFi Provisions. Mixed outcome. Centralized exchanges (Coinbase stock) benefit from clear registration pathways. But DeFi faces compliance burdens that could drive activity offshore. Bifurcated market: CeFi up, DeFi down. Consider reducing DeFi exposure and increasing Bitcoin/ETH held on regulated platforms.

 

Scenario C: Bill Fails or Stalls. The bear case. Regulatory uncertainty continues. SEC enforcement by litigation remains the norm. Risk-off for altcoins as legal clouds persist. Bitcoin dominance increases as the only "clearly not a security" asset. Defensive positioning: overweight BTC, underweight altcoins, avoid tokens with ongoing SEC scrutiny.

Scenario	Probability	Winners	Losers
A: Full Passage + DeFi Carve-Out	35%	ETH, DeFi tokens, exchanges	Offshore platforms
B: Passage with Restrictions	40%	Coinbase, compliant tokens	DeFi, privacy coins
C: Bill Fails	25%	Bitcoin (safe haven)	Altcoins, all tokens under SEC cloud

🪙 Staking Tax Rules Before You Rebalance →

🏛️ SEC Official: Digital Assets Guidance →

❓ 7. FAQ — 10 Critical Questions Answered

Q1: What is the crypto market structure bill?

Comprehensive legislation that would establish clear SEC and CFTC jurisdiction over crypto assets, create registration pathways for exchanges, and provide the first federal framework for classifying digital assets as securities or commodities.

Q2: When is the January 15 markup?

The Senate Banking and Agriculture committees will hold synchronized markups on January 15, 2026. This is when committee members debate and amend the draft legislation before voting to advance it.

Q3: How would Bitcoin be classified?

Bitcoin would be officially classified as a commodity under CFTC jurisdiction. This has been the agency's position for years, but the bill would codify it into law, ending any remaining ambiguity.

Q4: What about Ethereum?

Ethereum's status is more complex. The bill's decentralization framework would likely classify ETH as a commodity, but this depends on how the final criteria are written. ETH's classification remains a key negotiation point.

Q5: Will DeFi be regulated?

The bill includes a DeFi carve-out for truly decentralized protocols. However, front-end interfaces may face some compliance requirements. The exact terms remain contentious and could change during markup.

Q6: How does this relate to the GENIUS Act?

The GENIUS Act (signed July 2025) regulates stablecoins specifically. The market structure bill addresses broader crypto assets and exchanges. Together, they form a comprehensive regulatory framework.

Q7: When could the bill become law?

Industry insiders target Q2-Q3 2026 for final passage, before midterm election campaigns consume congressional attention. However, legislative timelines are unpredictable—delays are common.

Q8: What happens if the bill fails?

Regulatory status quo continues. The SEC would maintain its "regulation by enforcement" approach, bringing cases against individual projects. Uncertainty persists, likely suppressing institutional investment.

Q9: Should I wait to invest until the bill passes?

Not necessarily. Markets often price in expected outcomes before legislation passes. If you believe the bill will pass, positioning before final votes could capture gains. But legislative risk cuts both ways.

Q10: How do I track the bill's progress?

Follow Congress.gov for official updates. CNBC, CoinDesk, and The Block provide real-time coverage. LegalMoneyTalk will publish analysis as major developments occur.

📅 Q1 2026 Crypto Tax Calendar — All Deadlines →

🏛️ CFTC Official: Digital Asset Resources →

⚠️ Legal Disclaimer

This article is for informational purposes only and does not constitute legal, tax, or investment advice. Legislative outcomes are uncertain and subject to change. Consult qualified professionals before making financial decisions based on pending legislation.

Image Disclosure: Images are AI-generated for illustrative purposes and do not represent actual government documents or legislative proceedings.

✍️ Author: Davit Cho, Global Asset Strategist & Crypto Law Expert

📋 Verification: IRS Notice 2024-56, Notice 2024-57, Final Regulations TD 9961

📅 Published: January 11, 2026

📧 Contact: davitchh@proton.me

Form 1099-DA Penalty Relief 2026 — What the IRS Won't Tell You

The IRS buried penalty relief provisions deep in Notice 2024-56. Most taxpayers will never find them. Here's how to use them before April 15.

Figure 1: The IRS's new Form 1099-DA launches in 2026 with built-in penalty relief provisions that most crypto investors don't know exist—creating a narrow window for compliance without punishment.

💡 Key Takeaways (30-Sec Summary)

• Penalty Relief Window: IRS waives penalties for 2025 transactions if brokers show "good faith" compliance efforts.
• FIFO Delay: Mandatory FIFO cost basis method postponed until 2026—you can still choose your accounting method for 2025.
• Backup Withholding Deferred: 24% backup withholding on crypto sales extended through 2026 under Notice 2025-07.

January 2026 marks a seismic shift in crypto taxation. For the first time, every major exchange must report your transactions directly to the IRS on Form 1099-DA. No more flying under the radar. No more "forgot to report" excuses. The era of crypto tax opacity is officially over.

 

But buried in the 300+ pages of IRS guidance lies something most taxpayers will never discover: comprehensive penalty relief provisions. The IRS knows this transition is messy. They know brokers aren't ready. They know cost basis tracking is a nightmare. So they built escape hatches—temporary relief that protects compliant taxpayers from punishment during this chaotic first year.

 

The problem? The IRS isn't advertising these provisions. They're buried in Notice 2024-56, Notice 2024-57, and scattered across multiple technical guidance documents. If you don't know where to look, you'll never find them. This article extracts every penalty relief provision, explains exactly how to qualify, and gives you the compliance roadmap to navigate 2026 tax season without fear.

 

In my view, this is the most important crypto tax article you'll read this year. Not because the rules are complex—they are—but because the relief provisions expire. Miss the window, and you're subject to full penalties. Use them correctly, and you buy yourself time to get compliant without financial punishment.

🛡️ 100% Ad-Free Experience

LegalMoneyTalk prioritizes your financial clarity. No sponsors. No affiliate bias. Pure analysis.

📋 Strategic Blueprint

• 📄 1. What Is Form 1099-DA? The Basics Explained
• 🛡️ 2. Notice 2024-56: The Hidden Penalty Relief Provisions
• 📊 3. FIFO Delay: Why Your Cost Basis Method Still Matters
• 💰 4. Backup Withholding Deferral Through 2026
• 🏢 5. Broker Reporting Requirements: What Exchanges Must Send
• ⚠️ 6. Common Mistakes That Void Your Penalty Relief
• ❓ 7. FAQ — 10 Critical Questions Answered

📄 1. What Is Form 1099-DA? The Basics Explained

Form 1099-DA is the IRS's new standardized reporting form for digital asset transactions. Starting with tax year 2025 (filed in 2026), every crypto broker, exchange, and custodian must report your sales, exchanges, and dispositions directly to the IRS. This is the crypto equivalent of the 1099-B form that stock brokers have used for decades.

 

The form captures critical transaction data: the date of sale, gross proceeds, cost basis (starting 2026), and whether the gain or loss is short-term or long-term. For 2025 transactions reported in early 2026, brokers are only required to report gross proceeds. Full cost basis reporting kicks in for transactions occurring on or after January 1, 2026.

 

This represents a fundamental shift in IRS enforcement capability. Previously, the agency relied on voluntary compliance and occasional subpoenas to exchanges. Now, they receive automatic transaction data matching capabilities. If your tax return doesn't match your 1099-DA, expect a CP2000 notice—or worse, an audit flag.

 

The Infrastructure Investment and Jobs Act (IIJA) of 2021 mandated this reporting requirement, giving the IRS four years to develop the form and regulations. The final rules, published in Treasury Decision 9961, establish the framework that every crypto investor must now navigate.

Tax Year	Reporting Requirement	What Brokers Report
2025 (Filed 2026)	Gross Proceeds Only	Sale date, proceeds amount
2026 (Filed 2027)	Gross Proceeds + Cost Basis	Full transaction details, gain/loss calculation
2027+ (Filed 2028+)	Complete Reporting	All data including wallet transfers

📘 Master the 1099-DA Basics — Complete First Year Guide →

🛡️ 2. Notice 2024-56: The Hidden Penalty Relief Provisions

Notice 2024-56 is where the IRS buried the gold. This technical guidance document, released alongside the final regulations, contains comprehensive penalty relief provisions that most taxpayers and even many tax professionals don't know exist. Understanding these provisions could save you thousands in penalties during this transition year.

 

The core relief provision states that for transactions occurring in calendar year 2025 (reported in 2026), the IRS will not impose penalties for failure to file or furnish Forms 1099-DA if the broker can demonstrate "good faith efforts" to comply with the new requirements. This means brokers get a pass on technical errors, late filings, and incomplete data—as long as they tried.

 

But here's what matters for taxpayers: this broker-level relief flows downstream. If your exchange sends you an incorrect or incomplete 1099-DA, you can rely on that form in good faith without penalty exposure. The IRS explicitly states that taxpayers who receive forms with errors are not penalized for reporting based on the information provided—provided they didn't know the information was incorrect.

 

The relief also extends to backup withholding failures. Normally, brokers must withhold 24% on payments to customers who fail to provide valid TINs. Notice 2024-57 defers this requirement through 2026, giving both brokers and taxpayers additional runway to sort out compliance issues without immediate financial penalties.

📌 Market Reality Check

The practical reality is that most exchanges are scrambling. Coinbase, Kraken, and Gemini have publicly acknowledged challenges in implementing the new reporting requirements. Cost basis tracking for assets transferred between wallets remains technically difficult. The IRS knows this—which is why they built in these relief provisions. Smart taxpayers use this window to get compliant, document their good faith efforts, and avoid the penalty hammer that will fall harder in 2027.

Relief Provision	What It Covers	Expiration
Broker Filing Penalty Waiver	Late/incorrect 1099-DA filings	Tax Year 2025 only
Good Faith Reliance	Taxpayer reliance on broker forms	Tax Year 2025 only
Backup Withholding Deferral	24% withholding requirement	Through December 31, 2026
FIFO Method Delay	Mandatory cost basis method	Until January 1, 2026

👨‍👩‍👧 Inherited Crypto? Special 1099-DA Rules Apply →

📊 3. FIFO Delay: Why Your Cost Basis Method Still Matters

Figure 2: The IRS's phased implementation timeline for 1099-DA reporting requirements, showing the critical transition from gross proceeds-only reporting (2025) to full cost basis disclosure (2026+).

One of the most significant relief provisions concerns cost basis accounting methods. Under the final regulations, brokers would be required to use the First-In-First-Out (FIFO) method for calculating cost basis starting in 2025. FIFO assumes you sell your oldest coins first—which often results in higher taxable gains for long-term holders who bought at lower prices.

 

The IRS delayed mandatory FIFO implementation until January 1, 2026, giving taxpayers one additional year to use their preferred accounting method. This is massive for tax optimization. If you've been using Specific Identification (selecting which lots to sell) or HIFO (Highest-In-First-Out) to minimize gains, you can continue through the end of 2025.

 

For the 2025 tax year, this means you still have flexibility. If you sold Bitcoin at $95,000 and have lots purchased at $60,000 (2024) and $20,000 (2021), you can specifically identify the $60,000 lot to minimize your gain. Under mandatory FIFO, you'd be forced to use the $20,000 lot first—creating a much larger taxable event.

 

Starting January 1, 2026, this flexibility disappears for broker-reported transactions. Brokers must default to FIFO unless you provide specific identification instructions before the sale. The practical implication: if tax optimization matters to you, get your cost basis records organized now, and provide specific lot instructions to your exchange before executing trades in 2026.

Method	How It Works	Tax Impact	2025 Status
FIFO	Sell oldest coins first	Often higher gains	Optional (mandatory 2026+)
LIFO	Sell newest coins first	Often lower gains	Available for 2025
HIFO	Sell highest cost first	Minimizes current gains	Available for 2025
Specific ID	Choose specific lots	Maximum control	Available (requires documentation)

📈 Cost Basis Wrong? IRS Takes 40% More — FMV Documentation →

💰 4. Backup Withholding Deferral Through 2026

Backup withholding is one of the most punishing IRS enforcement mechanisms—and crypto investors nearly faced it in 2025. Under normal rules, if you fail to provide a valid Taxpayer Identification Number (TIN) to your broker, they must withhold 24% of your gross proceeds and remit it directly to the IRS. For a $100,000 Bitcoin sale, that's $24,000 withheld immediately.

 

Notice 2025-07 extended the deferral of backup withholding obligations for digital asset sales through calendar year 2026. This means exchanges don't have to withhold that 24%—even if your TIN is missing or mismatched—giving both brokers and customers time to resolve identification issues without immediate cash flow consequences.

 

This relief is particularly important for international users of U.S. exchanges, customers who opened accounts years ago with incomplete information, and anyone who has changed their legal name or TIN since account creation. Without this deferral, millions of crypto users would face unexpected withholding on every sale.

 

The catch: this is a deferral, not an elimination. Starting January 1, 2027, backup withholding applies in full force. If your exchange is flagging TIN issues now, resolve them before the end of 2026. Once withholding kicks in, getting that money back requires filing a tax return and waiting months for a refund—cash flow you may need.

Timeline	Backup Withholding Status	Action Required
2025	Deferred	None immediate
2026	Deferred (Final Year)	Verify TIN with all exchanges
2027+	Fully Enforced (24%)	Withholding on non-compliant accounts

🌾 DeFi Transactions? Different Rules Apply →

🏢 5. Broker Reporting Requirements: What Exchanges Must Send

Figure 3: Comparison of broker reporting obligations under the new 1099-DA regime—showing the phased implementation from gross proceeds only (2025) to full cost basis and gain/loss reporting (2026+).

Not all crypto platforms are created equal under the new rules. The IRS definition of "broker" determines who must file 1099-DA forms. Centralized exchanges like Coinbase, Kraken, Gemini, and Binance.US clearly qualify. They custody your assets, process your trades, and know your identity—making them natural reporting entities.

 

Decentralized exchanges (DEXs) and DeFi protocols occupy a grayer zone. The final regulations include provisions for "DeFi brokers"—front-end interfaces that facilitate trades—but enforcement mechanisms remain unclear. For 2025-2026, most DEX activity will likely escape 1099-DA reporting, though taxpayers remain responsible for self-reporting regardless of whether they receive forms.

 

What brokers must report for 2025 transactions (your first 1099-DA arriving in early 2026): gross proceeds from each sale or exchange. This includes crypto-to-crypto trades—swapping ETH for BTC is a taxable event reported on the form. Brokers are not required to report cost basis for 2025, though many will include it voluntarily if available.

 

Starting with 2026 transactions (reported in 2027), brokers must include cost basis for "covered securities"—assets acquired on or after January 1, 2023, on that same platform. Assets transferred in from external wallets or purchased before 2023 may show "N/A" for basis, leaving taxpayers responsible for tracking and reporting their own cost basis.

Platform Type	1099-DA Required?	Notes
Centralized Exchanges (CEX)	Yes	Coinbase, Kraken, Gemini, etc.
Custodial Wallets	Yes	If they facilitate sales
DEX Front-Ends	TBD (2027+)	Regulations pending enforcement
Self-Custody Wallets	No	No broker relationship
P2P Transactions	No	Self-reporting required

🪙 Staking Rewards on 1099-DA? Know the Rules →

⚠️ 6. Common Mistakes That Void Your Penalty Relief

Penalty relief isn't automatic. The IRS grants it based on "good faith" compliance—which means you can lose protection through carelessness, negligence, or willful disregard. Understanding what voids your relief is just as important as knowing it exists.

 

Mistake #1: Ignoring the Digital Asset Question. Form 1040 now includes a mandatory checkbox asking whether you received, sold, exchanged, or disposed of digital assets. Checking "No" when the answer is "Yes" is considered a false statement under penalty of perjury. Even if you qualify for penalty relief on reporting errors, lying on your return voids all protections.

 

Mistake #2: Failing to Report Known Income. If you received staking rewards, airdrops, or mining income that you know is taxable, not reporting it isn't covered by the 1099-DA penalty relief provisions. Relief applies to form filing issues—not to taxpayers who simply don't report income they know they owe.

 

Mistake #3: Intentionally Providing False Basis. When your exchange can't calculate cost basis (common for transferred-in assets), you must provide it yourself. Fabricating a higher basis to reduce gains is tax fraud—not a good faith error covered by relief provisions. Keep documentation: purchase records, blockchain timestamps, exchange statements.

Mistake #4: Missing Form 8949 Entirely. The 1099-DA flows to Form 8949 (Sales and Other Dispositions of Capital Assets). Even if your broker's form has errors, you must still file Form 8949 with your return. Penalty relief doesn't excuse you from filing—it protects you from penalties when you file with good faith reliance on broker data.

🚩 IRS Audit Red Flags — Avoid Getting Flagged →

❓ 7. FAQ — 10 Critical Questions Answered

Q1: When will I receive my first Form 1099-DA?

Brokers must furnish 1099-DA forms by February 15, 2026, for tax year 2025 transactions. However, under transitional relief, forms may arrive later—some taxpayers might receive them after the April 15 filing deadline, requiring amended returns.

Q2: What if my 1099-DA has errors?

Report based on what you believe is correct, attach an explanation statement, and keep documentation of your actual basis. You qualify for good faith reliance protection if you used the broker's data reasonably and corrected obvious errors.

Q3: Does penalty relief apply to taxpayers or just brokers?

Both. Brokers get relief from filing penalties; taxpayers get relief from accuracy penalties when they rely in good faith on broker-provided information. The provisions work in tandem.

Q4: Is DeFi activity reported on 1099-DA?

Not yet for most protocols. The IRS has proposed regulations for DeFi brokers, but enforcement is delayed. You must still self-report DeFi income regardless of whether you receive a form.

Q5: Can I still use HIFO or Specific ID for 2025 transactions?

Yes. Mandatory FIFO doesn't begin until January 1, 2026. For 2025 transactions, you can use any consistent, reasonable method with proper documentation.

Q6: What is backup withholding and does it apply to me?

Backup withholding requires brokers to withhold 24% from sales if you haven't provided a valid TIN. It's deferred through 2026 for crypto—but verify your exchange accounts have correct tax IDs before 2027.

Q7: Do I need to report crypto-to-crypto trades?

Yes. Swapping BTC for ETH is a taxable event. Your 1099-DA will report the gross proceeds from each trade. You must calculate and report the gain or loss on Form 8949.

Q8: What if I transferred crypto between wallets?

Transfers between your own wallets are not taxable events. However, brokers may report them as potential dispositions. Keep records showing the transfer was to yourself—same cost basis carries over.

Q9: How long does penalty relief last?

Filing penalty relief applies to tax year 2025 only. Backup withholding deferral extends through 2026. Starting 2027, full enforcement begins with no transitional relief.

Q10: Should I file an extension to wait for late 1099-DAs?

Consider it if you expect multiple late forms. An extension gives you until October 15 to file—but pay estimated taxes by April 15 to avoid interest. File Form 4868 for an automatic 6-month extension.

📅 Full 2026 Crypto Tax Calendar — Key Deadlines →

⚠️ Legal Disclaimer

This article is for informational purposes only and does not constitute legal, tax, or investment advice. Tax laws are complex and change frequently. Consult a qualified tax professional for advice specific to your situation. LegalMoneyTalk is not a law firm or CPA practice.

Image Disclosure: Images are AI-generated for illustrative purposes and do not represent actual IRS forms or official government documents.

🏛️ IRS Official: Notice 2024-56 Penalty Relief Guidance →