Questions To Ask A Crypto CPA Before You Hire One

A photo of Chris Herbst, Managing Director at global crypto tax reporting firm, CountDeFi & CH Consulting. CBAP (CIBA), GTP (SAIT).
By Chris Herbst
Managing Director at global crypto tax reporting firm, CountDeFi & CH Consulting
CBAP (CIBA), GTP (SAIT)
Category
Published On
Updated On
Update Due
IRS Crypto Tax
September 19, 2026
September 19, 2026
July 16, 2027
Ask a crypto CPA who reconciles the wallet history, who signs the return, and what they do when a cost basis is missing. The IRS holds you accountable for every item on your return, so the answers matter more than the credential alone. Ten questions, and what a weak answer sounds like.

What A Crypto CPA Actually Does, And Where The Work Usually Stops

A crypto CPA is a licensed accountant who prepares and signs your tax return, and who can represent you before the IRS if that return is ever questioned. The licence covers the filing and the representation. It says nothing about whether the person can rebuild a year of on-chain activity, and that is the half of the job most crypto holders actually need done.

The IRS is explicit about what the credential buys. Its guidance states that "enrolled agents, certified public accountants, and attorneys have unlimited representation rights before the IRS", and may represent clients "on any matters including audits, payment/collection issues, and appeals". Everyone else who prepares returns for pay holds limited rights at best, as set out on the IRS page covering tax return preparer credentials and qualifications.

The licence and what it buys you

The licence buys you a signature and a right of audience. A CPA has passed a uniform exam, carries a state licence and can stand in front of the IRS on your behalf for any matter. If you are facing a notice, an examination, or several unfiled years, that authority is what you are paying for and no unlicensed provider substitutes for it.

What the licence does not certify is protocol knowledge. There is no crypto module in the CPA exam and no register of who has decoded a concentrated liquidity position or a perpetual futures funding stream. A CPA who files a hundred returns a year for salaried clients holds the same licence as one who has rebuilt fifty DeFi books. The questions below exist because the credential cannot tell those two apart.

The part of the job that is not accounting

Before anyone can prepare a crypto return, somebody has to turn wallets, exchange exports and on-chain activity into a defensible ledger with a cost basis attached to every disposal. That is data reconstruction, and it is engineering work. The IRS puts the record-keeping duty on you, not on your exchange: its guidance tells taxpayers to keep records documenting "your purchase, receipt, sale, exchange or any other disposition of the digital assets", which you can read on the IRS digital assets page.

So the first thing to establish on any call is which side of that line your prospective CPA sits on. The table below is the engagement you are trying to map.

The workWho normally does itThe question that tests it
Pulling wallets and exchange history into one ledgerA reconciliation specialist, or nobodyWho imports my wallets, you or me?
Matching transfers between your own accountsReconciliation specialistHow do you stop my own transfers showing as sales?
Decoding LP, staking, perps and bridge activityReconciliation specialistWhich protocols have you rebuilt before?
Fixing missing or zero cost basisReconciliation specialistWhat do you do when an acquisition is missing?
Preparing Form 8949 and Schedule DCPA, EA or attorneyWill you sign the return?
Responding to an IRS notice on that returnCPA, EA or attorneyAre your representation rights unlimited?

If one person or firm genuinely covers every row, that is a complete engagement. If they cover the bottom two and assume you will arrive with the top four already done, you have not found a full service, you have found a preparer. Both are legitimate. Only one of them finishes your year. We set the two roles out side by side in crypto CPA vs crypto tax accountant.

Ten Questions To Ask A Crypto CPA On The First Call

Ask these in order. Each one has a shape of answer that tells you the person has done this work before, and a shape that tells you they are hoping your data arrives clean.

1. Who reconciles my wallet history, you or me?

This is the question that decides the engagement, so ask it first. A strong answer names the work and claims it: we import your wallets and exchange accounts, we match the transfers, we price the disposals, and you review the result. A weak answer redirects to software, as in export a CSV from your tracker and send it over. That answer means the reconciliation is yours, and the fee you were quoted does not cover the part of the job that takes the longest.

2. Which chains and protocols have you rebuilt before?

You want specifics that match your own history, not a list of logos. Somebody who has done the work will talk about how a particular protocol behaves, which events it emits and where the tracker gets it wrong. Somebody who has not will answer with the name of their software. The distinction is whether they describe the protocol or describe a tool.

3. What do you do when a cost basis is missing?

Missing basis is the normal condition of a crypto book, not an edge case, so the answer to this reveals more than almost any other question. A good answer describes tracing: following the asset back through the wallets and venues it moved through until the acquisition is found, and documenting what was checked when it cannot be. A weak answer says they will use zero, or they will estimate. Defaulting to zero basis inflates your gain on every affected disposal. We walk through the tracing process in how to fix missing cost basis.

4. Will you sign my return, and is your PTIN on it?

A paid preparer has a legal duty here and it is worth hearing them confirm it. The IRS states that "a paid tax return preparer is primarily responsible for the overall substantive accuracy of your return and by law, is required to sign the return and include their preparer tax identification number (PTIN) on it", which appears in IRS Topic no. 254 on choosing a preparer. A preparer who takes a fee and leaves the signature line blank is what the IRS warns about when it tells taxpayers to avoid unethical "ghost" return preparers, and it is a reason to walk away.

5. Which accounting method will you use, and can you support it?

Ask which method they intend to apply and how they will evidence it. Digital assets are property for US tax purposes, so gains are computed lot by lot and the method you use has to be supportable from records rather than asserted at filing. The answer you want describes how the lots are tracked and where the supporting detail lives. The answer you do not want is that the software decides.

6. What do you do when my exchange forms disagree with my wallets?

Broker reporting on Form 1099-DA has made this a live question for every US crypto holder, because a broker only sees the activity on its own platform. When you move an asset in from a self-custody wallet, the broker frequently has no acquisition to report against the disposal. A capable preparer will tell you they reconcile the two and document the difference. A weak answer takes the form at face value and reports whatever number it carries.

7. Can I see a sample report before I commit?

Ask for a redacted example of what you will receive at the end. A firm that produces real reconciliation output will have something to show: a gains schedule, a disposal listing, a statement of how positions were treated. A firm that has nothing to show, or offers only a screenshot of a dashboard, is telling you that the deliverable is the software's export rather than their work.

8. What happens if the IRS writes to me about this return?

You are asking two things at once here: whether they will handle it, and whether they are allowed to. Only attorneys, CPAs and enrolled agents hold unlimited representation rights, so an unlicensed preparer cannot represent you on an appeal or a collection matter even for a return they prepared. If a notice is a realistic prospect for you, this answer decides the hire.

9. How is the fee calculated, and what changes it?

A fee should be tied to something you can see, usually transaction volume and the number of venues and protocols involved, with a stated trigger for when it moves. Be wary of the shape the IRS itself warns about: Topic no. 254 advises taxpayers to "avoid tax return preparers who base their fees on a percentage of the refund". We set out what the market actually charges in how much a US crypto CPA costs.

10. What exactly do you need from me, and in what format?

A specific answer here is the clearest evidence that someone has run this process before. They will ask for wallet addresses rather than screenshots, full-history API keys or complete exports rather than a single tax year, and a list of every venue you have used including the dead ones. A vague answer, such as send whatever you have, means the scoping happens after you have paid.

How To Tell If They Have Handled Your Protocols, Not Just Your Asset Class

The fastest test is to make the question concrete rather than categorical. Most providers can answer yes to do you handle DeFi, because the question invites a yes. Very few can describe what happens to a specific position in their process.

Name your three hardest venues

Pick the three things in your own history you least understand, and ask how each one is treated. A liquidity position you opened and closed, a perpetual futures account with funding payments, a bridge that changed the token's identity, a validator you delegated to. Say the names out loud and ask what happens to them.

Ask for the shape of the answer, not a yes

Follow up with how, and listen for whether the reply contains mechanism. Someone who has handled it will tell you what the position becomes in the ledger, whether a disposal is recognised, and where the basis goes. Someone who has not will restate that their software supports the chain. Support for a chain means the tracker can read the transactions, not that anybody has decided what they are.

The Answers That Tell You The Reconciliation Is Being Subcontracted

Some firms sell a complete crypto service and pass the hardest part straight back to you, so it is worth learning to recognise it early. The signals are consistent and they show up in the first conversation.

The first is a quote given before anyone has asked how many wallets and venues you hold. Reconciliation effort scales with venues and protocols, so a number produced without that information is a number for preparation alone. The second is any version of just export from your tracker, which moves the judgement calls, the missing basis and the mismatched transfers onto you while the fee stays where it is.

The third is the absence of any question about what you still hold. Closing balances are the only external check on whether a reconstruction is right: if the ledger says you hold assets you do not, something upstream is wrong. If what you need is a clean, reconciled file for a preparer you already trust, that is a defined product, and we describe it in crypto tax reports for your CPA.

Who Is Accountable If The Return Is Wrong

You are, and every question above is worth asking because of it. The IRS puts it plainly in Topic no. 254: "although the tax return preparer always signs the return, you're ultimately accountable for the accuracy of every item reported on your return." A preparer's signature adds their responsibility to yours. It does not move yours anywhere.

This is also why the reconciliation question outranks the credential question for most people. A licensed preparer working from an unreconciled ledger produces a correctly formatted return built on wrong numbers, and the accountability for those numbers sits with you. Verify the credential, by all means: the IRS maintains a directory of preparers and explains how to check one on its choosing a tax professional page. Then ask where the numbers come from.

What A Thin Set Of Answers Means, And What To Do Next

Thin answers do not always mean the wrong provider, but they do mean an incomplete engagement. Most crypto returns involve two distinct jobs, and it is perfectly sound for two different people to do them: a reconciler who rebuilds the history, and a licensed preparer who files it and stands behind it.

If the CPA in front of you answers questions four, eight and nine well and questions one, two and three poorly, you have found your preparer and you still need your reconciliation. If they answer one, two and three well but cannot sign your return, you have found your reconciler and you still need a filer. Deciding which half you are missing is the point of the call, and it is easier once you know which you already have. Our guide to whether you need a crypto CPA covers how to verify a licence properly.

CountDeFi is not a CPA firm and does not file returns. We are US crypto tax accountants who reconcile the full transaction history across exchanges, wallets and DeFi protocols, resolve missing cost basis, and produce IRS-ready reports that your own CPA or enrolled agent files. If that is the half you are missing, our crypto tax accounting service is built for it.

Frequently Asked Questions

What should I ask a crypto CPA in a first call?

Start with who reconciles the wallet history, because it decides the scope and the fee. Then ask which protocols they have rebuilt, what they do when a cost basis is missing, whether they will sign the return with their PTIN, and how the fee is calculated. Those five separate a full service from a preparation-only engagement.

How do I know if a CPA really understands DeFi?

Name three specific positions from your own history and ask what happens to each one in their process. Someone who has handled them will describe the mechanism: whether a disposal is recognised, what the position becomes in the ledger, and where the cost basis goes. Someone who has not will answer by naming the software they use.

Should I ask a crypto CPA for a sample report?

Yes, and a redacted example is a reasonable request that an established firm can meet. What you are checking is whether the deliverable is their own reconciliation output, with a gains schedule and a disposal listing, or simply an export from a tax tracker with a cover page attached.

Can a CPA file my crypto return without reconciling my wallets?

They can, and many do, which is why the question matters. The return will be correctly formatted and built on whatever numbers you supplied. The IRS holds you accountable for the accuracy of every item on the return, so an unreconciled ledger remains your exposure regardless of who signed the filing.

What if my CPA says my exchange forms are enough?

Treat it as a reason to probe further, because a broker only reports what happened on its own platform. Assets you moved in from self-custody often arrive with no acquisition attached, so the form can show a disposal with nothing to set against it. Reconciling the forms against your own wallet history is what closes that gap.

Do I need both a crypto CPA and a crypto tax accountant?

Frequently yes, and it is a normal arrangement rather than a sign something has gone wrong. The reconciliation and the filing are different disciplines, and the common structure is a specialist who rebuilds the transaction history and produces the reports, and a licensed CPA or enrolled agent who files them and represents you if questioned.

How much should a crypto CPA charge for a first call?

An initial scoping conversation is usually free. The fee you should expect to discuss on that call is tied to the number of venues, wallets and protocols involved, because that is what drives the work rather than the size of your portfolio.


Chris Herbst is the founder of CountDeFi, a crypto tax specialist whose qualifications span investment management, financial analysis, mathematical statistics and computer science. He holds the Chartered Business Accountant in Practice (CBAP) designation with the Chartered Institute for Business Accountants (CIBA) and the General Tax Practitioner (GTP) designation with the South African Institute of Taxation (SAIT). His combined background in investments, accounting and tax, mathematical statistics and computer science underpins his work in complex crypto tax reporting. 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. View our Editorial Policy.

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