The IRS now knows who’s trading crypto, but it still can’t tell if anyone owes tax. That’s the reality of the new 1099-DA reporting system that just went live, and it’s about to affect every tax professional with crypto clients.
On a recent episode of the Earmark Podcast, host Blake Oliver sat down with Lawrence Zlatkin, Vice President of Tax at Coinbase, to explain what the new 1099-DA form reports, where the gaps are, and what changes Coinbase is pushing for in Washington. With a front-row seat to crypto taxation’s biggest challenges, Lawrence offered insight on where the system works (and where it doesn’t).
The problem is that the IRS’s new reporting brings crypto tax enforcement into the mainstream, but the underlying framework creates massive overreporting with little tax benefit. Treating stablecoins as property and requiring reports on tiny gas fees generates millions of forms that tell the government almost nothing about actual tax liability. Tax professionals must bridge the gap between what the IRS receives and what matters for computing taxes.
The 1099-DA: What’s There and What’s Missing
Think of the 1099-DA as crypto’s version of the 1099-B that brokers send for stock trades. The basic concept is familiar: the form goes to your client and the IRS, and the government matches what taxpayers report against what exchanges report. Tax pros have worked with this system for decades.
But this first-year version is bare-bones. As Lawrence explained, “We are implementing the system barely 18 months after Congress issued the regulations. The 1099-B system was developed over a period of five years, and even longer for gross proceeds.”
The result is a “skeletal version” that reports just two things: who the customer is and their gross proceeds from transactions. The critical missing piece is cost basis.
“We’re including basis for our customers for informational purposes, but that information is not actually going to the government,” Lawrence said. Next year, exchanges will start reporting basis, but only when they have it.
Blake walked through a simple example. Say your client sells Bitcoin for $100. The IRS gets a 1099-DA showing $100 in gross proceeds. But if your client bought that Bitcoin for $90, the actual taxable gain is just $10. That $10 is the only number that matters for taxes, but it’s invisible to the government this year.
The problem worsens with transfers between wallets and exchanges. When crypto leaves Coinbase for a self-custody wallet or another exchange, the basis tracking breaks. “The only person who knows what’s in a non-custodial wallet is you because you’re the owner,” Lawrence explained. When that crypto returns to an exchange, there’s no way to reconstruct what happened in between.
So what’s the point of all this reporting? Lawrence was candid. “The government’s concern has been that there’s been underreporting and noncompliance in the ecosystem generally. So what this achieves from their standpoint is they find out who’s really participating.”
Until now, the IRS’s only crypto signal was that checkbox on the 1040, which Lawrence diplomatically called “gobbledygook.” It asks about digital asset transactions. Now the IRS will see actual dollar amounts attached to names. They’ll spot whales with millions in proceeds. They’ll identify non-filers.
“There’s nothing nefarious or awful or evil about that,” Lawrence said. “It’s just that they will have that information they didn’t otherwise have before.”
The practical takeaway is, “you are in control of your tax data,” Lawrence emphasized. Clients who consolidate their activity on a single exchange will have better records. Coinbase provides transaction history and gain/loss data through its “position service.” But clients bouncing between exchanges and wallets need to maintain their own records. Nobody else can do it for them.
The Stablecoin Problem: When Property Isn’t Property
Missing basis data would be manageable if the tax framework made sense. It doesn’t, especially for stablecoins.
Since 2014, the IRS has classified all crypto as property rather than currency or cash equivalents. This includes stablecoins like USDC, which are designed to trade at exactly $1. Every time your client uses USDC, that’s a reportable disposition of property.
“Stablecoins are designed to be stable and consistent and traded at par with the US dollar,” Lawrence said. “99.9% of the time, it’s intended to trade within a fraction of a decimal of the US dollar. So in essence, we’re not reporting a gain or loss. So it’s over-reporting of data. There’s no fundamental purpose for that. I would argue that the only reason for that is surveillance.”
The scale is significant. Coinbase must report stablecoin transactions exceeding $10,000 to the government. Hundreds of thousands of customers received 1099s this year that include these transactions. And taxpayers must report even smaller amounts. Coinbase just won’t tell the IRS about those.
Blake offered his own example. Earmark uses USDC to pay vendors for international transactions where stablecoins are faster than traditional banking. Under current rules, every payment is a reportable property disposition. “It’s as if the IRS got every bank transaction,” Blake said. “Americans would never stand for that. We’d call that surveillance and overreach.”
Lawrence revealed this isn’t hypothetical. Five years ago, the Treasury Department proposed requiring banks to report credit card transactions over $10,000 in aggregate. “That was quashed for the reasons you just described,” he said. Yet here we are with stablecoins.
There’s a small silver lining. “The tax system is based on income. If there’s no gain or loss, there’s no taxable income, and there’s no penalty,” Lawrence explained. You can’t underpay taxes on zero gain. But the reporting requirement still exists.
De Minimis Madness: When Pennies Become Paperwork
Beyond stablecoins, tiny transactions that generate enormous paperwork are another reporting nightmare.
Gas fees, which are the network costs for blockchain transactions, often involve disposing of pennies or fractions of dollars worth of Ethereum. Each one is technically a property disposition that must be tracked and reported. Each might have actual (if microscopic) gain or loss.
The volume is staggering. Coinbase files millions of 1099-DAs containing hundreds of millions of underlying transactions that feed into Form 8949. Lawrence estimates that about half qualify as de minimis, meaning they’re essentially meaningless for tax purposes.
“We’re not going to pave roads and solve the deficit on the backs of de minimis reporting for crypto,” Lawrence argued. He’s pushing for a threshold below which transactions become exempt from reporting or taxation. Should it be $5? $50? $200? Should it be income-based or transaction-based?
“At what point do we stop requiring reporting for transactions?” Lawrence asked. “If the IRS gets bombarded with billions of transactions that are tiny in nature because people are required to report them, the system itself breaks.”
These billions of transactions are being reported today, and the IRS’s ancient computer systems must somehow process them all.
The Washington Agenda: Common Sense Reforms in Political Gridlock
Lawrence came with a clear policy agenda that included ten priorities, although the conversation covered highlighted six in detail.
Beyond stablecoins and de minimis thresholds, Coinbase is pushing for the following reforms:
- Crypto lending should work like securities lending. “You’re not disposing of crypto because you’re going to get the same amount back,” Lawrence explained. Under current securities rules, that’s not taxable. Crypto should be the same.
- Staking rewards timing. The IRS says rewards are taxable when received. Others argue they shouldn’t be taxed until sold. “That’s a source of friction and debate,” Lawrence noted.
- Charitable deductions are perhaps the clearest absurdity. Donate over $5,000 in Bitcoin, and you need a formal appraisal. “You can type it in Google and get a Bitcoin price, just like you get the price of any stock or security,” Lawrence said. Bitcoin has “readily ascertainable fair market value.” The appraisal requirement is “ridiculous.”
- Foreign investment rules. The US has safe harbors that allow non-US persons to trade securities through US brokers without triggering US tax. No equivalent exists for crypto. “We’re the best and safest market in the world,” Lawrence said. “We’d like to preserve that for crypto, not just for regular old investment assets.”
So why hasn’t anything passed?
“I’m cautiously optimistic,” Lawrence said. President Trump has been supportive. He met with Coinbase CEO Brian Armstrong last week. The White House issued a report on digital assets, including tax provisions. Treasury has been “by and large very supportive.”
But Congress is the bottleneck. The House is narrowly Republican-controlled, and crypto has become more partisan than it should be. “This should not be a partisan debate,” Lawrence insisted. “This ecosystem benefits Democrats and Republicans.”
The Clarity Act for crypto regulation is under discussion. So is broader tax reform. But as Lawrence diplomatically put it, “Things don’t move as quickly as we might like in Washington.”
What This Means for Tax Professionals
The picture Lawrence painted is clear, even if the rules aren’t. The 1099-DA tells the IRS who’s trading and how much, but it lacks the cost basis needed to determine actual tax liability. Tax professionals must fill that gap by reconciling gross proceeds against basis records scattered across exchanges, wallets, and spreadsheets.
Meanwhile, classifying stablecoins as property without de minimis rules creates millions of reportable transactions with zero tax consequences. It’s all noise, no signal.
The reforms Coinbase wants make sense. But with narrow Congressional majorities and partisan friction, don’t expect relief before next filing season.
The message for practitioners is crypto is no longer niche. With millions of 1099-DAs arriving and IRS matching letters sure to follow, you need to understand what these forms show, how to help clients track basis, and where the traps are. Firms that build this expertise now will serve a growing client base. Those who don’t risk being blindsided along with their clients.
“Everyone wants to talk about tax,” Lawrence joked at the start. By the end, it’s clear why. The intersection of crypto and tax is where innovation meets regulation, and right now, regulation is playing catch-up.
Listen to the complete episode of the Earmark Podcast for Lawrence’s full breakdown of Coinbase’s policy priorities and practical advice on basis tracking. You can earn free NASBA-approved CPE credit by listening and taking a short quiz at earmarkcpe.com.
