In This Article
- What Is Form 1099-DA and Why 2025 Is Different
- What Every Exchange Must Report (and What They Don't)
- Platform-by-Platform Comparison Table
- Coinbase: What to Watch For
- Kraken: The Krak App Trap
- Gemini: Default FIFO Warning
- Robinhood, Binance.US, and Crypto.com
- PayPal, Venmo, and Cash App
- What About DeFi, Non-Custodial Wallets, and Foreign Exchanges?
- Rev. Proc. 2024-28: The Wallet-by-Wallet Rule
- How to Reconcile When Exchange Numbers Don't Match
- Multiple Exchanges: Putting It All Together
- Frequently Asked Questions
What Is Form 1099-DA and Why 2025 Is Different
Form 1099-DA is the IRS's new information return for digital asset transactions. Treasury Decision 10000 (TD 10000), published June 2024, implemented IRC Section 6045 for digital assets, making 1099-DA mandatory for broker-effected transactions beginning with Tax Year 2025. This is the first year exchanges must report your crypto proceeds to the IRS on a standardized form.
The critical gap: for TY2025, brokers must report gross proceeds only (Box 1f). Cost basis reporting is entirely voluntary. Mandatory basis reporting begins for covered digital assets acquired on or after January 1, 2026. This means most taxpayers will receive 1099-DAs showing proceeds with blank or zero basis — and the IRS will see those same proceeds numbers. If you file without providing your own accurate basis on Form 8949, the IRS treats your full proceeds as taxable gain.
Recipient copies were due by February 17, 2026. Notice 2024-56 provides penalty relief for brokers making good-faith efforts for TY2025. Notice 2025-33 extended backup withholding relief through calendar year 2026. Late and corrected forms are a real possibility this first year.
What Every Exchange Must Report (and What They Don't)
Required on every 2025 Form 1099-DA:
- Gross proceeds (Box 1f) — proceeds reduced by allocable fees per Reg. Section 1.6045-1
- Date of disposition
- Digital asset identifier (DTIF code or 9-digit identifier)
- Quantity of units disposed
- Box 9 "Noncovered" checkbox — checked for virtually all 2025 transactions because all pre-2026 acquisitions are permanently noncovered
NOT required for 2025:
- Cost basis / adjusted basis
- Date acquired
- Short-term vs. long-term classification
- Wallet addresses (required in final regs but subject to transition relief)
Some brokers voluntarily report basis on the customer copy. If yours does, verify it before relying on it — under Notice 2024-56, brokers are shielded from penalties for inaccuracies in optional data.
What goes on other forms (not 1099-DA):
- Staking rewards and referral bonuses: Form 1099-MISC (at the $600 threshold or above)
- Derivatives and regulated futures: Form 1099-B
- Crypto payments for goods/services: Form 1099-K (at $20,000/200 transactions under OBBBA)
- IRA transactions: Form 5498 (contributions) and Form 1099-R (distributions)
Platform-by-Platform Comparison Table
| Exchange | 1099-DA | 1099-MISC | Other Forms | Basis to IRS (2025) | Key Quirk |
|---|---|---|---|---|---|
| Coinbase | Yes | Yes (staking, referrals at $600+) | 1099-B (derivatives) | No | Aggregates same-asset same-day transactions; stablecoin aggregation above $10K |
| Kraken | Yes | Yes (staking, income at $600+) | None | No | Krak App sends = treated as reportable dispositions on 1099-DA |
| Gemini | Yes | Yes (staking, referrals at $600+) | None | No | Default cost basis method is FIFO if user did not pre-select |
| Robinhood | Yes | Yes (rewards at $600+) | 1099-B (securities), 1099-R | No | Consolidated 1099 mixes crypto and securities — separate carefully |
| Binance.US | Yes | Yes (staking, referrals at $600+) | None | No | Operated at reduced capacity post-SEC action; verify account data |
| Crypto.com | Yes | Yes (Earn, referrals at $600+) | 1099-B (futures/options) | No | Visa card spend creates layered tax events (disposal + reward) |
| eToro | Yes | Consolidated | 1099-INT, 1099-DIV | No | Multi-asset form covers crypto, stocks, ETFs — separate carefully |
| PayPal | Yes | Yes (bonuses at $600+) | 1099-K (goods/services) | No | Three possible forms from one platform |
| Venmo | Yes | No | 1099-K (goods/services) | No | Provides supplemental gain/loss statement (customer copy only) |
| Cash App | Yes | No | 1099-B (legacy) | No | Bitcoin only; transitioning from 1099-B to 1099-DA for TY2025 |
Not issuing 1099-DA: Non-custodial wallets (Exodus, Trust Wallet), foreign exchanges (Binance.com, Bybit, OKX, KuCoin, Gate.io, Bitfinex, MEXC), IRA platforms (iTrustCapital, Bitcoin IRA — IRA-exempt trades), prediction markets like Kalshi (uses 1099-INT, 1099-MISC, 1099-B for crypto transfers only).
Coinbase: What to Watch For
Coinbase issues 1099-DA for all dispositions on Coinbase and Coinbase Advanced. Same-asset, same-day transactions are aggregated into a single line item. Stablecoin sales are aggregated (not transaction-by-transaction) once cumulative proceeds exceed $10,000. Gas fees are included in the 1099-DA reporting per Reg. Section 1.6045-1.
Coinbase also issues 1099-MISC for staking rewards and referral bonuses at the $600 threshold, and 1099-B for Coinbase Derivatives Exchange activity. These are separate income streams flowing to different lines on your return.
Key warning: Coinbase has publicly noted that transferred-in assets will show no basis. Their advocacy director stated: "Until we get there, there'll be a lot of confusion." If you moved crypto from another exchange or from self-custody to Coinbase and then sold, your 1099-DA will show full proceeds with no basis offset. You must provide your own basis on Form 8949.
Kraken: The Krak App Trap
Kraken issues 1099-DA for all dispositions on Kraken, Kraken Pro, and the Krak App. The deadline for TY2025 forms was March 13, 2026.
The Krak App sharp edge: Sending crypto via the Krak App's payment/send feature is treated as a reportable disposition and included on your 1099-DA. If you "sent" crypto to a friend or merchant through the Krak App, you may find unexpected entries on your 1099-DA for transactions you didn't think of as sales. Confirm each line against your actual transaction history.
Kraken also issues 1099-MISC for staking rewards and other income at the $600 threshold.
Gemini: Default FIFO Warning
Gemini issues 1099-DA for all dispositions, with forms available in February 2026. Gemini also issues 1099-MISC for staking rewards and refer-a-friend bonuses.
Important: If you did not select a cost basis method in Gemini's settings before your first 2025 sale, Gemini defaulted to FIFO. The gain/loss shown on your customer copy may differ from what was transmitted to the IRS (proceeds only for 2025). If your preferred method is HIFO or Specific ID, the customer copy numbers will not reflect your actual tax position. You must reconcile using your own records.
Robinhood, Binance.US, and Crypto.com
Robinhood includes crypto reporting in a consolidated 1099 alongside securities (1099-B). The crypto section is the 1099-DA; the securities section is the 1099-B. Basis may appear on the customer copy but was NOT sent to the IRS for 2025, creating a false sense of compliance. Stablecoin sales are aggregated above $10,000 in cumulative proceeds.
Binance.US operated at substantially reduced capacity through 2024 following SEC enforcement. They suspended USD services and planned to restore them in early 2025. If you continued crypto-only trading, you should receive a 1099-DA. Verify your current account status and data completeness before relying on the form.
Crypto.com issues 1099-DA for dispositions. The Crypto.com Visa card creates layered tax events: (1) card spend in crypto is a disposal of crypto, and (2) card rewards may be income or a purchase rebate depending on the program terms. This requires separate analysis. Crypto.com also issues 1099-B for regulated futures and options activity.
PayPal, Venmo, and Cash App
PayPal may send you three separate forms: 1099-DA (selling crypto), 1099-K (accepting crypto as payment for goods/services above the $20,000/200 transaction threshold), and 1099-MISC (bonuses). These are different income types flowing to different return lines. PayPal historically restricted transfers in and out, so transferred-in assets will show no basis.
Venmo issues 1099-DA and provides a supplemental gain/loss statement with more detail than most platforms. However, this basis information is customer-copy only — not sent to the IRS.
Cash App (Bitcoin only) is transitioning from 1099-B to 1099-DA for TY2025. Transferred Bitcoin shows zero or blank basis. Lightning Network tax treatment remains unresolved.
What About DeFi, Non-Custodial Wallets, and Foreign Exchanges?
Non-custodial wallets (Exodus, Trust Wallet, MetaMask, Ledger) do not issue any 1099-DA. They are not custodial brokers — private keys are held by the user. All transactions (in-wallet swaps, sends, receives, DeFi interactions) must be self-tracked using block explorers (Etherscan, Solscan) and crypto tax software.
DeFi protocols (Uniswap, Aave, Compound, Curve) also do not issue 1099-DAs. The DeFi broker reporting rule (T.D. 10021) was repealed by Congress via the Congressional Review Act (H.J.Res.25, signed April 10, 2025). All DeFi transactions remain fully taxable — they simply have no information return. You must self-report on Form 8949.
Notice 2024-57 permanently exempts six transaction types from broker reporting: wrapping/unwrapping (Section 3.02), liquidity provider transactions (Section 3.03), staking transactions (Section 3.04), crypto lending (Section 3.05), crypto short sales (Section 3.06), and notional principal contracts (Section 3.07). These exemptions affect broker reporting obligations only — your tax obligations on these transactions remain unchanged.
Foreign exchanges (Binance.com, Bybit, OKX, KuCoin, Gate.io, Bitfinex, MEXC) do not issue 1099-DAs to U.S. persons. All gains must be self-reported. FBAR obligations (Form FinCEN 114) may apply if aggregate foreign account balances exceeded $10,000 at any point during the year. FATCA reporting (Form 8938) applies at higher thresholds ($50,000 single / $100,000 MFJ at year-end).
Rev. Proc. 2024-28: The Wallet-by-Wallet Rule
Effective January 1, 2025, Rev. Proc. 2024-28 requires wallet-by-wallet cost basis tracking. The universal (cross-wallet, cross-account) pooling method that many traders used through TY2024 is no longer available.
What this means in practice:
- Each exchange account and each wallet is a separate cost basis pool
- Your FIFO, LIFO, HIFO, or Specific ID method must be elected and applied separately for each account
- A method elected on Coinbase does NOT carry over to Kraken
- Transferring crypto between your own accounts creates "noncovered" status on the receiving side — the receiving broker has no visibility into your original purchase price or date
This dramatically increases complexity for active traders using multiple platforms. Cross-account optimization strategies that minimized tax by selectively selling high-basis lots across exchanges are no longer permissible.
How to Reconcile When Exchange Numbers Don't Match
Run a 3-way reconciliation for every exchange:
- 1099-DA proceeds — the number the IRS received
- Exchange transaction CSV — your complete transaction history downloaded from the platform
- Your own records / crypto tax software — Koinly, CoinTracker, CoinLedger, or your spreadsheet
Common sources of mismatch:
- Stablecoin aggregation: exchanges may aggregate qualifying stablecoin sales under the $10,000 threshold, meaning some transactions appear on the CSV but not the 1099-DA
- Fee treatment: Box 1f should reflect proceeds reduced by allocable fees per Reg. Section 1.6045-1. If your CSV shows gross proceeds before fees, the numbers will differ by the fee amount
- Transferred-in assets: the 1099-DA shows full proceeds with no basis. Your records must supply the basis
- Multiple 1099s from one platform: TikTok Shop sellers know this problem — you may receive both 1099-DA (for crypto sales) and 1099-MISC (for staking) from the same exchange, and both need to appear on your return in different places
If your Form 8949 total substantially differs from the sum of your 1099-DAs, the IRS automated matching system will flag the return. Document every difference and keep your reconciliation workpapers. An adjustment on Form 8949 Column (g) with the appropriate code in Column (f) is how you formally reconcile.
Multiple Exchanges: Putting It All Together
A typical crypto investor in 2025 might have:
- 1099-DA from Coinbase (spot trades)
- 1099-DA from Kraken (additional trades)
- 1099-MISC from Coinbase (staking rewards)
- 1099-MISC from Kraken (staking income)
- No forms from MetaMask or Uniswap (but taxable activity occurred)
All of this flows to Form 8949 (for dispositions) and Schedule 1 Line 8z or Schedule C (for staking/ordinary income). Under Rev. Proc. 2024-28, each exchange's transactions are tracked with per-account basis. Your crypto tax software must be configured for wallet-by-wallet tracking.
If any exchange shows proceeds that you believe are incorrect, do NOT ignore the 1099-DA. File with the correct numbers, include the 1099-DA adjustment on Form 8949, and keep documentation. The worst outcome is filing without addressing a 1099-DA the IRS received.
Need a CPA to reconcile your 1099-DAs across multiple exchanges? Learn about our 1099-DA Reconciliation Service or explore our crypto tax services.
Related reading: The 1099-DA $0 Basis Trap | Your First Form 1099-DA | Crypto Gas Fees: Tax Deductible? | Crypto Tax Services
## Frequently Asked Questions
Which exchanges send Form 1099-DA for Tax Year 2025?
All major U.S. custodial exchanges send 1099-DA: Coinbase, Kraken, Gemini, Robinhood, Binance.US, Crypto.com, eToro, PayPal, Venmo, and Cash App. Non-custodial wallets (Exodus, Trust Wallet) and foreign exchanges (Binance.com, Bybit, OKX, KuCoin) do not.
Does the 1099-DA include my cost basis?
Not for TY2025. Brokers are required to report gross proceeds only. Cost basis reporting becomes mandatory for covered digital assets acquired on or after January 1, 2026. You must reconstruct and provide your own basis on Form 8949.
What is a "noncovered" digital asset on Box 9?
Every digital asset acquired before January 1, 2026 is permanently noncovered. This means the broker will never report its cost basis to the IRS, even in future years. Transferred-in assets are also noncovered regardless of acquisition date, because the receiving broker has no visibility into your original purchase.
What do I do if my 1099-DA seems wrong?
Do not ignore it. File with the correct numbers on Form 8949, and use Column (f) and Column (g) to reconcile any differences from the 1099-DA. Keep your exchange CSV, transaction records, and reconciliation workpapers as documentation in case of IRS inquiry.
Does DeFi activity appear on 1099-DA?
No. The DeFi broker reporting rule was repealed by Congress in April 2025. All DeFi transactions (swaps, liquidity pools, lending, staking) must be self-reported. Notice 2024-57 permanently exempts six categories of complex transactions from broker reporting, though they remain fully taxable.
How does Rev. Proc. 2024-28 affect my taxes?
Starting January 1, 2025, you must track cost basis separately for each exchange account and each wallet. Universal (cross-wallet) pooling is no longer permitted. Your cost basis method (FIFO, LIFO, HIFO, Specific ID) must be elected per account, not globally.
What about staking rewards — are those on 1099-DA?
No. Staking rewards are reported on Form 1099-MISC, not 1099-DA. The IRS views staking rewards as ordinary income (an accession to wealth under IRC Section 61), not as a disposition of digital assets. Both forms may come from the same exchange.
Do I need to report crypto from foreign exchanges?
Yes. All gains must be self-reported on Form 8949 and Schedule D. Additionally, you may have FBAR obligations (Form FinCEN 114) if aggregate foreign account balances exceeded $10,000 at any point during the year, and FATCA reporting obligations (Form 8938) at higher thresholds.
