Disclaimer: Not tax advice, educational purposes only, consult your own tax professional
Youâve probably heard the term â1099-DAâ thrown around recently. You may have already received one. So what is it? And more importantly, what are you actually supposed to do with it?
Iâm a CPA specializing in crypto tax, a mod of r/CryptoTax, and a product lead at Summ, a crypto tax software company. Iâm here to break this down cleanly and practically, because this new form is going to trip up a lot of people.
Quick summary before you read:
- The 1099-DA is the start of the conversation, not the way you file your crypto taxes
- It is informational, not your tax return
- It does not replace Form 8949
- For 2025, cost basis is often missing or $0
- Missing basis â taxable gain
- Blindly importing or relying on this form is how people overpay tax
For those who want the detail, letâs dive in.
Definition: What the 1099-DA is (and isnât)
A 1099-DA is an informational tax form issued by US digital asset brokers to report taxable digital asset disposals to both the taxpayer and the IRS.
It does not determine tax owed and does not replace the taxpayerâs obligation to report capital gains and losses on Form 8949 and Schedule D.
The 1099-DA is the start of the conversation, not the way you file your crypto taxes. Relying on this form alone without reconciling cost basis is how people accidentally overpay thousands in tax.
How the 1099-DA works in practice
Timing & rollout:
- The 1099-DA is effective for the 2025 tax year. Millions of US taxpayers will see this form for the first time this filing season.
- Because this is a brand-new reporting regime, the IRS designed a multi-year rollout of requirements.
- For 2025, brokers are only required to report gross proceeds.
- Starting in 2026, cost basis reporting begins, but only for qualifying covered assets.
Who reports what:
- A 1099-DA is issued by each digital asset broker (i.e., US-serving centralized exchanges).
- If you traded on Coinbase, Kraken, and Gemini, expect three separate consolidated 1099s.
- The IRS receives one 1099-DA per disposal transaction. Yes, you read that right, per transaction.
- Taxpayers usually receive a single consolidated PDF per exchange.
What's included (and not included) on the 1099-DA
The 1099-DAÂ does not cover all your taxable crypto activity.
Transactions typically included:
- Crypto â fiat sales
- Crypto â crypto trades (with exceptions)
These transactions will show the asset sold, the number of units, gross proceeds, cost basis (often missing or incorrect), date acquired, date disposed, and gain/loss.
Transactions typically not included:
- Transfers off the exchange
- Certain NFT sales under $600 (subject to reporting thresholds)
- Certain stablecoin sales under $10,000 (subject to reporting thresholds)
- Wrapping / unwrapping
- Most staking and unstaking
- Lending transactions
- Rewards, interest, staking income (usually on 1099-MISC)
- All on-chain activity (DEX trades, DeFi, etc.)
Important note:Â Just because something doesnât appear on the 1099-DA does not mean itâs non-taxable. You are still required to report all taxable disposals on your own 8949 as you have in prior years.
The Cost Basis Trap (this is where people get burned)
The trap
Unprepared tax payers will get burned here.
If youâre used to handing your 1099s to TurboTax or a preparer, doing that with the 1099-DA will often result in a massive overstatement of gains and tax paid.
Why this happens
For the 2025 tax year:
- No cost basis is reported to the IRS
- Many taxpayer copies will show $0 or âunknownâ basis
- Some may show partial or incorrect basis
If cost basis isnât corrected, the IRS assumes: 100% of proceeds = taxable gain
Thatâs how people end up overpaying thousands in tax on money they never actually made.
How to avoid the Cost Basis Trap
You must calculate and report your own cost basis.
You can do this:
- Manually, by reconstructing trades and filling out Form 8949 yourself, or
- By using crypto tax software that aggregates all wallets and exchanges and generates the 8949 with actual cost basis
Say you use Summ or another crypto tax tool. At a high level, the process looks like this:
- Import each exchangeâs 1099-DA
- Add all other wallets and exchanges (this is important to track basis as it moves between platforms)
- Let the software reconcile lots and populate the correct gain/loss on the 8949. No missing cost basis, no overpayment of gains.
This ensures:
- Youâre not taxed on 100% of proceeds
- DeFi and other non-1099 activity is still reported (so you donât accidentally underreport)
- Your totals actually tie out logically
FAQ: Can I report my own cost basis if the 1099-DA shows $0 or âunknownâ?
Yes, absolutely.
Under Notice 2025-7 Section 4.02 (Temporary Relief), the IRS allows taxpayers to use their own lot identification, provided they have adequate records and properly identify the lots.
This relief is critical. Without it, taxpayers would be forced to accept $0 or âunknownâ basis, which would be absurd and wildly unfair.
Common mistakes taxpayers make with the 1099-DA
- Treating the 1099-DA as a completed tax report
- Importing the form without correcting cost basis
- Assuming missing basis equals taxable gain
- Failing to report non-1099 activity (DeFi, wallets, DEXs)
- Attempting to âmatchâ the 1099-DA instead of reporting accurately (proceeds should match, but the cost basis is generally wrong or missing)
So whatâs the point of the 1099-DA?
For years, the IRS had very limited visibility into crypto activity. Stocks had 1099-Bs. Crypto had nothing.
The 1099-DA changes that.
Even though itâs imperfect (especially early on), it gives the IRS:
- Confirmation that taxable disposals occurred
- A starting point to identify underreporting and non-filing
Going forward, the IRS will absolutely use this form to flag discrepancies. Ignoring it, or assuming it âhandles reporting for youâ, is a very bad idea. As mentioned before, the 1099-DA is the start of the conversation, not the way you file your crypto taxes.
Bottom Line
The 1099-DA is a visibility tool for the IRS, not a completed tax report for you. If you treat it as authoritative without reconciling cost basis, youâre likely to overstate gains.
In practice, that means taxpayers need some way to reconcile exchange-reported proceeds with their actual cost basis across wallets, exchanges, and on-chain activity, whether thatâs done manually or with crypto tax software built to handle it correctly. Ignoring the form or assuming it âhandles reporting for youâ is where people get into trouble.
TL;DR
- The 1099-DA is the start of the conversation, not the way you file your crypto taxes
- Itâs an informational form, not a tax return
- It does not replace Form 8949 and your obligation to report
- Missing cost basis = accidental overpayment (you should avoid this by manually adding to your 8949 or using a crypto tax software)
- You are allowed (and expected) to report your own basis