IRS Guidelines on Digital Asset Reporting 2025

A photo of our CEO, Chris Herbst who has degrees in both in accounting and computer science - the very tools needed to handle crypto tax reporting correctly.
By Chris Herbst

Insights

Managing Director at global crypto tax reporting firm, CountDeFi & CH Consulting
GTP, CIBA
Category:
Updated:
Update Due:
Airdrops & Forks
May 4, 2026
January 1, 2027
The IRS is no longer playing catch-up when it comes to digital assets. With stricter regulations, expanded reporting requirements, and global coordination on the horizon, staying compliant has never been more important, or more complex.

Digital asset reporting is no longer a gray area. It is a critical compliance requirement that continues to evolve under increasingly sophisticated tax authorities.

In the U.S., the Internal Revenue Service (IRS) has taken a more assertive stance in recent years, tightening regulations around digital assets and expanding enforcement tools to identify non-compliance.

From simple buys and sells to complex decentralized finance (DeFi) activity, NFTs, and staking rewards, the reporting requirements now span a wide range of transactions, each with different tax implications. For global investors, understanding and applying these IRS guidelines correctly is essential, even when operating across multiple jurisdictions.

This guide explores the IRS guidelines, common challenges digital asset investors face, and how to stay compliant without the headache.

What Changed in IRS Guidelines

In 2023 and 2024, several significant developments have reshaped how digital assets must be reported:

1. Expansion of Form 1099 Reporting

The Infrastructure Investment and Jobs Act now requires "brokers" of digital assets, including centralized exchanges, to issue Form 1099-DA (Digital Asset) to users starting in the 2025 tax year. This means the IRS will receive direct data from platforms you use.

Implication: If you fail to report your transactions, the IRS may already know about them.

2. Refined Definitions of Income and Capital Events

  • Buying digital assets: Not taxable.
  • Selling digital assets: Taxable event.
  • Trading digital asset for digital asset: Taxable event.
  • Spending digital assets: Taxable event (capital gain or loss on the disposed coin).
  • Mining or staking rewards: Treated as ordinary income at the FMV when received.
  • Airdrops and hard forks: Income at FMV when you gain control of the asset.
  • NFTs: Taxable when sold or exchanged, but classification (collectible vs capital asset) still evolving.

3. Global Enforcement is Expanding

Though this article focuses on IRS compliance, digital asset reporting is going global. The OECD Crypto-Asset Reporting Framework will standardize digital asset disclosures across borders. Many U.S. taxpayers using offshore exchanges may be subject to FBAR or FATCA reporting obligations as well.

CountDeFi Tip: Even if your country does not yet enforce digital asset disclosures, regulations are tightening globally. Preparing now ensures you are audit-ready, in any jurisdiction.

Common Mistakes to Avoid

Mistakes in digital asset reporting are more common than many realize. Here are key pitfalls to avoid:

Failing to Report Digital Asset Activity

Even small trades or NFT flips must be reported. The IRS has added a yes/no digital asset question on Form 1040. Answering "no" while transacting can be considered perjury.

Mixing Personal and Business Use

If you receive digital assets as payment for goods or services, it is business income and must be reported differently than capital gains.

Ignoring Wallet-to-Wallet Transfers

While not taxable, these must be tracked to preserve cost basis and transaction history. Failing to do so can result in overpaying tax or incomplete records.

Inaccurate Cost Basis or FMV

Many platforms do not track cost basis across wallets or exchanges. Manual tracking errors are common, especially with long DeFi chains or obscure tokens.

Poor Recordkeeping

The IRS requires detailed logs of every transaction: date, amount, cost basis, FMV, and gain or loss. Without complete records, your position is easily challenged during an audit.

When to Seek Professional Help

Given the complexity of digital asset taxation, professional guidance is essential if:

  • You have traded on multiple platforms or across centralized and decentralized exchanges.
  • You have engaged in DeFi protocols, liquidity pools, or NFT marketplaces.
  • You earn staking, mining, or yield farming rewards.
  • You are unsure how to report airdrops or token swaps.
  • You are receiving IRS letters, audits, or CP2000 notices.

What To Look For in a Professional

Find someone who specializes in digital asset reporting and reconciliation for global and U.S. taxpayers. It is better to find a team who uses tools, rather than to try to use the tool yourself, to help simplify even the most complex DeFi activity.

Your chosen team should be able to assist with:

  • Audit-Ready Digital Asset Tax Reports
  • Transaction Classification Across All Wallets and Exchanges
  • Integration with Major Platforms (Coinbase, Binance, Metamask, Ledger, etc.)
  • Form 8949 and Schedule D Generation
  • Global Reports for Expats, U.S. Citizens Abroad, and Dual Residents
  • Support for Income, Capital Gains, NFTs, Mining, and Airdrops

Chris Herbst is the founder of CountDeFi, a crypto tax specialist with degrees in both accounting and computer science, and a registered Tax Professional (GTP, CIBA). This article is for educational purposes only and does not constitute tax, legal, or investment advice. Consult a qualified tax professional for guidance specific to your situation.

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