A16z Submits Feedback on IRS Cryptocurrency Tax Draft
The a16z comments on the IRS's draft Form 1099-DA, and the a16z comments and observations are summarized below:
Each digital asset transaction requires multiple brokers to file Form 1099-DA, creating unnecessary duplicate information reporting and placing an unreasonable burden on filers.
Requiring brokers to report wallet addresses is unnecessary and places sensitive taxpayer information at significant risk.
The cost of providing the information required by the 1099-DA form is prohibitive, and in some cases even impossible.
The final rule should delay or "progressively advance" the effective date of digital asset information reporting requirements.
Non-custodial wallets and digital asset payment processors should be removed from the category of "brokers" listed in Form 1099-DA.
The IRS should not require the filing of Form 1099-DA when disposing of fiat-backed stablecoins and most disposals of non-convertible tokens.
The requirement to file a Form 1099-DA should include a minimum threshold that should allow brokers to aggregate transactions for reporting purposes.