Key Takeaways:
- Brokers send 1099-DA in 2025; missing basis triggers CP2000 risks.
- Maintain complete acquisition records; reconcile transfers to prevent overstated taxable income.
- If CP2000 arrives, submit dated reconciliation showing correct basis and transfers.
The Internal Revenue Service is gaining clear visibility into your digital asset sales because brokers will send Form 1099-DA beginning with the 2025 tax year. Many of those forms will show gross proceeds but omit cost basis, which increases the chance that automated IRS matching treats sales as unreported gains and generates a CP2000 notice. As reported by Fortune, warning letters to crypto users have already spiked when broker-reported sales did not align with filed returns.
Cost basis is the amount you paid for a digital asset, typically including purchase price and certain fees; it is essential to determine gain or loss when you sell or exchange. When basis is missing or cannot be substantiated, taxable income can be overstated because only the sale side is visible. According to FinanceFeeds, the IRS defines fair market value as the open‑market price agreed upon by informed, willing parties, which underscores why accurate acquisition and sale records matter.
To prepare, consolidate complete records from every exchange and wallet you used, including self‑custody. Reconcile transfers between platforms so the same coins are not double counted as taxable disposals, and document acquisition dates, amounts, and transaction fees tied to each sale.
If you receive a CP2000 notice, compare the broker-reported proceeds to your records, then respond with a dated reconciliation that shows the correct basis and any transfer histories that explain missing acquisition data. Holland & Knight notes that taxpayers should maintain detailed records for all cryptocurrency transactions and that noncompliance can trigger accuracy-related penalties, so documentation quality directly affects outcomes.
KPMG analysis indicates that brokers must report gross proceeds from sales, swaps, and certain exchanges starting in 2025, while basis reporting becomes mandatory for some transactions beginning in 2026. This staggered approach reflects that many platforms lack reliable acquisition data when assets were moved from other venues or self‑custody.
According to Coinbase, as reported by LiveBitcoinNews, Form 1099-DA will require brokers to include stablecoins, gas fees, and all crypto sales starting with the 2025 tax year. For users, this means more comprehensive transaction-level reporting to the IRS even when the broker cannot determine what you originally paid.
Practitioners caution that mismatches arise when the IRS sees proceeds without basis and attempts to reconcile those figures against your return. “The IRS computer will see, for example, that a taxpayer has one million dollars of sales and a 1099-DA with no basis, and it will treat the basis as zero. If it cannot match what you report on your return, it’s going to send a notice automatically,” said Sharon Yip, CPA, at ChainwiseCPA, as reported by Forbes.
In practical terms, the transition looks like this: 2025 forms emphasize proceeds visibility across digital asset disposals, while 2026 begins limited basis reporting where a broker has sufficient acquisition history. Taxpayers still bear the burden to substantiate their own basis and should expect that transfers and self‑custody can disrupt a broker’s view.
At the time of this writing, Bitcoin trades near $66,373, a neutral data point that underscores why accurate basis, not price swings alone, drives taxable results. In equity markets, Coinbase Global shares recently fluctuated around the mid‑$160s, providing context for the operational backdrop as platforms implement 1099‑DA.
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