The Impact of Recent IRS Guidelines on Crypto Tax Reporting

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
Published:
Updated:
Update Due:
August 7, 2025
December 24, 2025
January 10, 2026
Crypto tax reporting is no longer a gray area — it’s 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 latest IRS guidelines, common challenges crypto investors face, and how to stay compliant without the headache.

Recent IRS Guidelines: What Changed?

In 2023 and 2024, several significant developments have reshaped how crypto 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 crypto: Not taxable.
  • Selling crypto: Taxable event.
  • Trading crypto-to-crypto: Taxable event.
  • Spending crypto: Taxable event (capital gain/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, crypto tax 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 doesn’t yet enforce crypto disclosures, regulations are tightening globally. Preparing now ensures you’re audit-ready — anywhere.

Common Mistakes to Avoid

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

1. Failing to Report Crypto 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.

2. Mixing Personal and Business Use
If you receive crypto as payment for goods or services, it’s business income and must be reported differently than capital gains.

3. 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.

4. 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.

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

When to Seek Professional Help

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

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

What To Look For in a Professional

Find someone who specializes in crypto tax reporting and reconciliation for global and U.S. taxpayers. It’s 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 Crypto Tax Reports
  • Transaction Classification Across All Wallets and Exchanges
  • Integration with Major Platforms (Coinbase, Binance, Metamask, Ledger, etc.)
  • Form 8949 & Schedule D Generation
  • Global Reports for Expats, U.S. Citizens Abroad, and Dual Residents
  • Support for Income, Capital Gains, NFTs, Mining, and Airdrops

FAQs

Q: What if I only made a few crypto trades — do I still have to report them?
A: Yes. Every taxable event — no matter how small — must be reported to the IRS.

Q: Is using decentralized exchanges (DEXs) a loophole to avoid taxes?
A: No. You are required to self-report all activity, even if the platform doesn’t issue tax documents.

Q: What if I lost access to a wallet or private keys?
A: You may be able to write off the loss, but this requires detailed evidence and should be reviewed by a tax professional.

Q: How far back should I keep records?
A: At least 6 years — especially if there is substantial income or if you anticipate future audits.

Final Thoughts

The IRS is no longer playing catch-up when it comes to crypto. With stricter regulations, expanded reporting requirements, and global coordination on the horizon, staying compliant has never been more important — or more complex.

For everyday investors and DeFi power users alike, understanding your tax obligations and maintaining accurate records is not just a legal requirement — it’s smart financial stewardship.

Whether you need to clean up years of trading history, prepare for your next filing, or ensure your reporting is audit-ready, we can help make it seamless and stress-free.

Crypto may be decentralized—but your tax reporting shouldn’t be.

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This content is general information, not  financial or investment advice. Always consider your own circumstances before acting.

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