Crypto Law Profile

Gross Proceeds and Basis Reporting by Brokers for Digital Assets (TD 10000)

U.S. Treasury and IRS rule requiring certain digital asset brokers to report gross proceeds and, in phases, adjusted basis on Form 1099-DA.

United States Effective Final Regulation Sep 9, 2024

At a glance

Status In force; Form 1099-DA reporting applies in phases beginning with 2025 transactions.
Jurisdiction United States federal tax information reporting rules issued by Treasury and the IRS.
Covered brokers Targets custodial platforms, hosted wallets, kiosks, and certain payment processors.
Phase-in Gross proceeds began in 2025; certain basis and real estate reporting began in 2026.

Bill details

Action

Last action
IRS published Notice 2026-20 extending temporary adequate-identification relief for digital asset units held in broker custody through 2026.
Last action date
Apr 6, 2026

Source

Source provider
Other official source
Source ID
TD 10000; FR Doc. 2024-14004
State legislature
Official bill page

Overview

Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions is a United States Treasury and Internal Revenue Service final regulation for digital asset information reporting. The rule was published as TD 10000 at 89 FR 56480 on July 9, 2024, corrected on August 16, 2024, and became effective on September 9, 2024. As of June 4, 2026, the core rule remains in force, with phased reporting on Form 1099-DA applying to covered broker transactions.

What the digital asset broker reporting rule covers

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.

Key provisions for U.S. digital asset tax reporting

  • 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.

Transition relief and deferred transaction categories

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.

Status and DeFi-rule distinction

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.

Jurisdictional impact

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.

Key provisions

Gross proceeds reporting

Requires certain digital asset brokers to file information returns and furnish payee statements reporting gross proceeds for covered sales beginning in 2025.

Reporting Jan 1, 2025 Source

Form 1099-DA reporting

Uses Form 1099-DA for broker reporting of digital asset proceeds; many 2025 forms were not expected to include basis information.

Tax forms Jan 1, 2025 Source

Adjusted basis phase-in

Phases in adjusted-basis reporting for certain covered digital asset transactions, generally beginning with assets acquired in broker custody in 2026.

Basis Jan 1, 2026 Source

Amount realized and basis rules

Provides rules for determining amount realized and basis when digital assets are sold, exchanged, or used in qualifying payment or real estate contexts.

Tax basis Jan 1, 2025 Source

Real estate reporting

Applies real estate reporting rules to closings involving digital asset consideration beginning in 2026.

Real estate Jan 1, 2026 Source

Custodial scope and DeFi distinction

Leaves non-custodial and certain decentralized finance broker issues outside TD 10000; separate DeFi broker regulations were later revoked.

Scope Sep 9, 2024 Source

Transition relief

IRS notices provide phased penalty, withholding, transaction-type, and basis-identification relief for digital asset broker reporting.

Relief Jul 15, 2024 Source

Timeline

  1. IIJA broker amendments enacted

    Congress enacted the statutory broker-reporting amendments implemented by TD 10000.

    Adopted Source
  2. Proposed regulations published

    Treasury and IRS published proposed digital asset broker-reporting regulations.

    Proposed Source
  3. Final rule announced

    Treasury and IRS announced final regulations and related transition guidance.

    Adopted Source
  4. TD 10000 published

    Final regulations were published in the Federal Register as 89 FR 56480.

    Published Source
  5. Correction published

    Corrections to TD 10000 were published at 89 FR 66563.

    Published Source
  6. Regulations effective

    TD 10000 and the August corrections became effective.

    Effective Source
  7. Gross proceeds phase began

    Gross proceeds reporting applied to covered digital asset sales beginning with 2025 transactions.

    In force Source
  8. Basis and real estate phase began

    Certain basis and real estate digital asset reporting rules began applying.

    In force Source
  9. Notice 2026-20 published

    IRS extended temporary adequate-identification relief for broker-custodied digital assets.

    Published Source

Who it affects

Actors

Custodial exchanges, Digital asset brokers, Digital asset kiosks, Hosted wallet providers, Investors, Payment processors, Real estate reporting persons

Asset classes

Cryptocurrencies, Digital assets, NFTs, Stablecoins

Official sources

Editorial note

Status verified against Federal Register and IRS sources on June 4, 2026. This profile is informational and does not provide legal, tax, investment, or trading advice.