US Gross Proceeds and Basis Reporting by Brokers for Digital Assets

The regulations implement broker-reporting amendments enacted through the Infrastructure Investment and Jobs Act. They generally require certain brokers to report gross proceeds from sales or exchanges of digital assets and, in phased circumstances, adjusted basis information. The rule also provides rules for determining amount realized and basis when digital assets are sold, exchanged, or used in payment or real estate contexts.

This profile covers TD 10000, not the separate decentralized finance broker rule later issued as TD 10021. TD 10000 focuses on custodial and intermediary broker models, including custodial digital asset trading platforms, hosted wallet providers, digital asset kiosks, and certain payment processors. The rule is best understood as an information-reporting framework rather than a standalone digital asset market-structure law.

• Gross proceeds reporting: Covered brokers must report gross proceeds for covered digital asset sales beginning with transactions on or after January 1, 2025.
• Form 1099-DA: The IRS created Form 1099-DA for digital asset proceeds reporting. The first reporting cycle covers many 2025 transactions, with recipient statements generally issued in early 2026.
• Basis reporting: Certain adjusted-basis reporting is phased in beginning in 2026, rather than applying fully to the first year of gross-proceeds reporting.
• Real estate transactions: Real estate reporting persons are brought into the digital asset reporting framework for closings involving digital asset consideration beginning in 2026.
• Scope limitations: TD 10000 does not finalize reporting for non-custodial decentralized finance participants. Treasury and the IRS treated those issues separately.

IRS materials also describe optional aggregate reporting mechanics for certain qualifying stablecoin and specified NFT transactions, as well as a de minimis threshold for some payment-processor activity. Those mechanics affect information reporting administration and should not be read as changing the substantive tax treatment of a transaction without separate authority.

IRS transition guidance narrows the near-term implementation burden. Notice 2024-56 provides penalty and backup-withholding transition relief for certain digital asset broker reporting obligations. Notice 2024-57 states that brokers are not required to report several categories of digital asset transactions until further guidance, including wrapping and unwrapping, liquidity provider activity, staking, lending, certain short sales, and notional principal contracts.

Later guidance continued that phased approach. Notice 2025-33 extends and modifies transition relief for backup withholding and related penalties. Notice 2025-7 and Notice 2026-20 address temporary relief for adequate identification of digital asset units held in broker custody, including alternative methods during the transition period.

The current status should be read carefully because two different Treasury decisions use similar digital asset broker-reporting language. TD 10000 remains the core final regulation for custodial broker gross-proceeds and basis reporting. By contrast, the later DeFi broker rule, TD 10021, was revoked under the Congressional Review Act and removed from the Code of Federal Regulations. That revocation does not, by itself, revoke TD 10000.

The rule applies at the U.S. federal tax level and is relevant to digital asset brokers, custodial exchanges, hosted wallet providers, kiosks, certain payment processors, real estate reporting persons, and taxpayers receiving digital asset broker statements. It is an information-reporting framework; it does not itself create an investment, trading, or compliance recommendation for readers. Crypto Laws editors should cross-link this profile to broader U.S. digital asset tax guidance and to the separate DeFi broker-reporting revocation profile, where available.