1099-DA Covered Securities Basis Reporting 2026: Practitioner Guide to Covered vs. Non-Covered Digital Assets

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The first Form 1099-DAs -- filed for the 2025 tax year in January 2026 -- reported gross proceeds from digital asset dispositions. Cost basis was not required. Starting with 2026 tax year transactions, brokers must report cost basis for covered digital assets alongside those proceeds. The first basis-bearing 1099-DAs will arrive in January 2027. For enrolled agents and CPAs who begin thinking about this now, in mid-2026, the covered/non-covered distinction is not a filing-season emergency: it is a client advisory opportunity. For those who wait until January 2027, it will be an emergency. See also our digital asset reporting overview for the broader Form 1099-DA and Form 8949 practitioner framework.

This guide addresses one narrow, high-stakes question: which digital assets will carry broker-reported basis on the January 2027 1099-DAs, which will not, and what the practitioner must do differently in each case. It covers the phased 1099-DA rollout, the covered/non-covered classification rules for digital assets, the 2026 form's box structure, stablecoin and specified NFT optional reporting elections, mixed-lot reconciliation, non-custodial wallet transactions, FBAR and PFIC cross-references, and a practitioner checklist for 2026 digital asset returns. All IRS positions cited here must be verified at IRS.gov before applying to any specific client situation.

The Phased 1099-DA Rollout: What Changed in 2026 and Why It Matters Now

Form 1099-DA reached its first real filing season with the 2025 tax year: brokers reported gross proceeds from digital asset dispositions, and practitioners saw 1099-DAs for the first time. But that first season was incomplete by design. Cost basis -- the figure that actually determines taxable gain or loss -- was not required for 2025 transactions. Box 1e (cost or other basis) was blank or not required for covered securities reporting purposes.

The 2026 tax year is where the transition completes for custodial broker accounts. Brokers are now required to report cost basis for covered digital assets, meaning the 1099-DAs issued in January 2027 for the 2026 tax year will carry both gross proceeds and basis for covered lots. For non-covered lots, basis remains blank and the taxpayer self-reports. This mirrors the structure that has governed equity reporting since the 2011-2013 phaseout for stocks, mutual funds, and bonds under IRC 6045: covered securities carry broker-reported basis; non-covered securities do not. Digital assets now follow the same framework, with January 1, 2026, as the covered/non-covered transition date for assets held in custodial broker accounts.

TIMING AT A GLANCE

2025 tax year (1099-DAs issued January 2026): Brokers reported gross proceeds only. Box 1e was blank or not required. Practitioners reconstructed basis from client records.

2026 tax year (1099-DAs issued January 2027): Brokers must report cost basis for covered digital assets. Box 1e will be populated for covered lots. Non-covered lots: Box 1e remains blank, Box 9 is checked, and the taxpayer self-reports basis.

The IRS may issue additional transitional relief extending the non-covered classification for specific asset classes or circumstances; verify current guidance at IRS.gov before filing any 2026 return.

What Makes a Digital Asset Covered vs. Non-Covered: The Rules That Control January 2027 1099-DAs

The covered/non-covered distinction for digital assets turns on two variables: when the asset was acquired, and where it was held. Both variables must be evaluated for every lot in the client's portfolio. The covered/non-covered definition for digital assets reflects current IRS and broker guidance; additional IRS guidance may refine or extend these rules; verify at IRS.gov before advising clients on classification.

Covered: the two conditions that must both be met

A digital asset is covered if it was acquired on or after January 1, 2026, AND it was held in a custodial broker account -- an account where the broker holds the private keys or otherwise maintains custody of the asset on the client's behalf. Both conditions are required. An asset acquired after January 1, 2026, but held in a self-custody wallet is not covered. An asset held at a custodial broker but acquired before January 1, 2026, is not covered.

Non-covered: the three situations that remove covered status

A digital asset is non-covered if any of the following applies: (1) it was acquired before January 1, 2026, regardless of when it was sold or which broker held it at the time of sale; (2) it was acquired in a non-custodial (self-custody) wallet, regardless of the acquisition date; or (3) it was transferred into a custodial broker account from a non-custodial source after January 1, 2026.

The third situation is the most common source of practitioner error. When a client moves digital assets from a hardware wallet into a custodial broker account, those assets are non-covered at the receiving broker even if the transfer happens well after January 1, 2026. The acquisition date controls, not the transfer date. If the client bought those assets in 2024 on a decentralized exchange and transferred them to Coinbase in March 2026, the assets arrive at Coinbase as non-covered lots.

On-chain rewards: staking, mining, and airdrops in custodial accounts

Digital assets received through staking rewards, mining income, or airdrops in a custodial account on or after January 1, 2026, are generally treated as covered. The basis for these assets is the fair market value at the time of receipt, which is also the amount includible as ordinary income. Verify the current IRS treatment at IRS.gov before applying this rule; the covered classification for on-chain rewards is subject to additional IRS guidance.

Mixed holdings at one broker

Most clients with any pre-2026 history will have a mix of covered and non-covered lots at the same broker -- for example, Bitcoin bought in 2021 (non-covered) sitting alongside Bitcoin bought in February 2026 (covered). The broker will report covered and non-covered transactions separately on the 1099-DA. Box 9 identifies non-covered transactions. Practitioners must handle each category differently at preparation time.

The Form 1099-DA Box Structure for 2026: What Each Box Tells the Practitioner

Form 1099-DA box numbering and instructions reflect the form as issued through 2026; verify against the current IRS instructions for Form 1099-DA at IRS.gov before filing. The following describes the boxes as they apply to covered and non-covered dispositions.

Covered dispositions: basis known, Box 9 unchecked

Digital asset name (Box 1a)

Identifies the digital asset by name or ticker symbol. When a client holds multiple asset types, each appears on a separate line with its own Box 1a entry. Verify the asset name against the client's exchange records; broker naming conventions may differ from common usage.

Number of units sold (Box 1b)

Reports the quantity of the digital asset disposed of. For fractional amounts, verify against the client's exchange transaction history. Significant discrepancies between Box 1b and client records may indicate a transfer that the broker is treating as a sale.

Date acquired (Box 1c)

The acquisition date controls the holding period: one year or less is short-term; more than one year is long-term. For covered assets, the broker reports this field. When Box 1c is blank on a covered transaction, investigate; the holding period classification affects the applicable tax rate.

Gross proceeds (Box 1d)

The total amount received from the disposition. This is reported for both covered and non-covered transactions. Box 1d alone does not determine taxable gain or loss; it must be combined with Box 1e (for covered assets) or self-reported basis (for non-covered assets).

Cost or other basis (Box 1e) -- the key change for 2026

For covered assets, the broker populates Box 1e with the cost basis. This is the defining change for the 2026 tax year. For non-covered assets, Box 1e is blank; the practitioner must supply basis from client records. A blank Box 1e on a 2026 1099-DA is no longer the expected first-year condition: it is the signal that the transaction is non-covered and the practitioner owns the basis work.

Accrued market discount (Box 1f)

Reports accrued market discount, if applicable. Most standard digital asset transactions will not have an entry here. If Box 1f is populated, verify the broker's treatment against the applicable rules and your client's holding history.

Wash sale loss disallowed (Box 1g)

Reports any wash sale loss disallowance. As of 2026, IRC 1091 wash sale rules apply to stock and securities, not property; digital assets are currently classified as property and are generally not subject to IRC 1091. If Box 1g is populated on a client's 1099-DA, investigate the broker's methodology before accepting the adjustment. IRS and Congress may extend wash sale rules to digital assets; verify current law at IRS.gov.

Short-term or long-term designation (Box 1h)

Reflects the broker's holding period determination: short-term (one year or less) or long-term (more than one year). Verify against Box 1c. If Box 1c shows an acquisition date but Box 1h appears inconsistent with that date, flag the discrepancy; the broker may have the wrong acquisition date on file.

Transaction type (Box 2)

Identifies the type of disposition: sale, exchange, or other disposition. An exchange of one digital asset for another is a taxable event; verify that the client's transaction history distinguishes sales from transfers, which are not dispositions.

Reported to IRS indicator (Box 6)

A code indicating whether and how the transaction has been reported to the IRS. Practitioners should note this box when determining the applicable Form 8949 checkbox (covered or non-covered) for the transaction.

Non-covered security indicator (Box 9) -- check this first

Box 9, when checked, tells the practitioner that this transaction is non-covered: Box 1e will be blank, basis is the practitioner's responsibility, and the transaction belongs in Form 8949 Box B or Box E (not Box A or Box D). Always check Box 9 first when reviewing a 1099-DA. The Box 9 check is the single most important diagnostic on the form for determining the practitioner's workload on that line item.

PRACTITIONER WORKFLOW NOTE: START WITH BOX 9

When reviewing a 2026 Form 1099-DA, check Box 9 before looking at any other field. Box 9 checked = non-covered; pull basis from client records. Box 9 unchecked = covered; use Box 1e as the starting basis, then reconcile against client records and document any discrepancy. This single check separates the low-effort covered lines from the high-effort non-covered lines and lets the practitioner scope the preparation work accurately before beginning.

Stablecoin and Specified NFT Optional Reporting: When the Absence of a 1099-DA Is Not Confirmation of Non-Taxability

The One Big Beautiful Budget Act (OBBBA) included provisions allowing brokers to elect to exclude certain stablecoin and specified NFT transactions from the full 1099-DA reporting requirements. This optional reporting election creates a gap between what a client receives in the mail and what actually happened in their account. The stablecoin and specified NFT optional reporting election reflects OBBBA provisions and transitional guidance; verify current broker election status and IRS guidance at IRS.gov before treating the absence of a 1099-DA as confirmation that a transaction need not be reported.

How the election works: broker-level, not transaction-level

The optional reporting election is made at the broker level, not on a transaction-by-transaction basis. If a broker elected out of stablecoin reporting, all stablecoin transactions at that broker may be excluded from the 1099-DA -- not just certain accounts or certain transaction sizes. Two clients at the same exchange may both have significant stablecoin activity and neither may receive a 1099-DA for it, if the exchange made the election.

Practitioner implication: self-reporting obligation survives the election

The broker's election not to report does not affect the taxpayer's reporting obligation. Stablecoin transactions remain taxable events -- and in particular, dispositions of stablecoins in exchange for other assets or cash are still capital gain or loss events (even if the gain or loss is typically small). The same self-reporting obligation applies to all digital asset transactions not covered by a 1099-DA, including specified NFTs excluded under a broker election.

During client intake for 2026 returns, ask specifically whether the client transacted in stablecoins or NFTs, even if no 1099-DA was received for those transactions. The absence of a form is not the end of the inquiry.

Mixed-Lot Reconciliation Workflow: Handling Covered and Non-Covered Lots at the Same Broker

The most common preparation scenario for an active crypto client will be a 1099-DA that contains both covered and non-covered transactions: pre-2026 holdings that are non-covered and 2026 acquisitions that are covered. The broker reports them side by side. The practitioner treats them differently. The following is the step-by-step reconciliation workflow.

Separate line items by Box 9 status

Sort every 1099-DA line item into two groups: Box 9 unchecked (covered) and Box 9 checked (non-covered). This determines the basis source and the Form 8949 checkbox for each transaction. Do this before touching any basis figures.

For covered lots: use Box 1e as the starting point, then reconcile

Box 1e is the broker's reported basis. Use it as the starting point, then compare it against the client's own records. Common broker basis errors include: missing the original purchase price for assets transferred in from another broker, incorrect lot identification when the client uses specific identification, and failure to account for fees paid at acquisition. If Box 1e matches the client's records, accept it. If it conflicts, use the correct basis, note the adjustment in Form 8949 Column G with the reason code, and document the reconciliation in the workpapers. If you cannot resolve the discrepancy, see the IRS transcripts guide at /irs-transcripts-tax-practitioners-guide.html for how to pull account information that may help.

For non-covered lots: pull basis from client records

Non-covered transactions require the practitioner to source basis independently. Preferred sources, in order: original purchase confirmations from the exchange, complete transaction history exports, cost-basis tracking software that imports API data from the exchange, bank or credit card records showing payments to the exchange, and the client's own contemporaneous records. Document what was used and why.

Report all dispositions on Form 8949

Covered transactions with matching broker basis go to Form 8949 Part I (short-term) or Part II (long-term) under checkboxes A or D, respectively. Non-covered transactions with self-reported basis go under checkboxes B (short-term) or E (long-term). Transactions with no 1099-DA at all go under checkboxes C (short-term) or F (long-term). Do not mix covered and non-covered transactions in the same checkbox grouping.

If the client has no records for non-covered assets

Options are limited to reasonable reconstruction: exchange history exports, blockchain explorer records, cost-basis tracking software output, and any contemporaneous records the client maintained. If reconstruction is not possible for certain lots, note the limitation in the workpapers, consider whether Form 8275 disclosure is appropriate, and document why zero basis is not the correct answer. Reporting zero basis when the practitioner has reason to know the client paid something for the asset is not a defensible position.

CLIENT COMMUNICATION: START DURING 2026, NOT JANUARY 2027

The single most effective thing a practitioner can do for clients with digital asset holdings is advise them now, in mid-2026, to maintain records of all acquisitions and transfers -- particularly for assets that will be non-covered when sold. A client who keeps accurate records through December 2026 arrives at filing time with the data the practitioner needs. A client who does not will face reconstruction in January 2027 using incomplete exchange histories. Advise all digital asset clients to: (a) document every acquisition date and price paid; (b) track all transfers between wallets and exchanges; and (c) retain exchange transaction history exports before exchanges change their data retention policies.

Non-Custodial Wallet Transactions: No 1099-DA, Full Self-Reporting Burden

Transactions executed in non-custodial (self-custody) wallets -- hardware wallets, software wallets, or any wallet where the taxpayer holds the private keys -- generate no Form 1099-DA regardless of when the assets were acquired or how large the transaction was. The full self-reporting burden remains on the taxpayer. This is true for 2026 transactions just as it was for prior years.

What the practitioner must do for non-custodial transactions

For each non-custodial wallet disposition, the practitioner must establish: (1) the date of acquisition, from client records; (2) the cost basis at acquisition, from client records; (3) the date of disposition, from blockchain explorer records or client records; (4) the gross proceeds, from client records or blockchain confirmation; and (5) the holding period (short-term or long-term), from the acquisition and disposition dates. Every non-custodial wallet disposition goes on Form 8949 under checkbox C (short-term) or checkbox F (long-term). No 1099-DA was issued, so there is no broker reporting to reconcile against.

Common practitioner errors with non-custodial wallet clients

The two errors that practitioners most often make with non-custodial wallet activity are: (1) assuming that no 1099-DA means no taxable event, which is incorrect -- the absence of a form does not exempt the transaction from reporting; and (2) treating non-custodial wallet transactions as exempt from reporting because the activity is "off-exchange," which is also incorrect. All digital asset dispositions are taxable events regardless of where they occur.

The 2026 hybrid client: custodial and non-custodial activity at once

Many active digital asset holders use both custodial exchanges and non-custodial wallets. In 2026, such a client may receive a 1099-DA from Coinbase or Kraken that covers their custodial transactions (with covered basis on post-2025 acquisitions) while their hardware wallet activity appears nowhere in any broker document. The practitioner must collect and report all transactions, including non-custodial ones, and cannot treat the 1099-DA as a complete picture of the client's digital asset activity.

FBAR and PFIC Cross-Reference: International Obligations That Run Alongside 1099-DA Reporting

Form 1099-DA covers domestic custodial broker reporting. It does not replace or satisfy the international reporting obligations that apply when a client holds digital assets through offshore accounts or foreign exchange platforms. Two cross-references practitioners should flag during digital asset intake are FBAR and PFIC.

FBAR (FinCEN Form 114): foreign exchange accounts

Digital assets held on foreign exchange accounts may trigger the FBAR filing requirement (FinCEN Form 114) if the aggregate value of all foreign financial accounts exceeds the applicable threshold during the calendar year. Do not rely on this guide for the threshold amount; verify the current FBAR reporting threshold at FinCEN.gov before advising clients, as thresholds are subject to regulatory change. A client who used a non-US exchange (Binance International, Bybit, or similar platforms not registered as US domestic brokers) during 2026 should be screened for FBAR exposure. See the FBAR foreign account compliance practitioner guide for the full screening workflow, FinCEN Form 114 filing procedure, and the interaction with Form 8938.

PFIC: foreign digital asset structures

Foreign digital asset holdings in certain fund or pooling structures may constitute passive foreign investment company (PFIC) interests under the passive income and asset tests. This is a fact-specific analysis that goes beyond routine 1099-DA reconciliation. If a client holds interests in a foreign digital asset fund, a foreign crypto hedge fund, or a similar structure, PFIC screening is appropriate before preparing the return. See the PFIC recognition and referral practitioner guide for the recognition criteria, Form 8621 requirements, and referral thresholds.

Practitioner Checklist for 2026 Digital Asset Returns

Use this checklist for every 2026 return with digital asset activity. Each item corresponds to a common failure mode that produces an incorrect return or a missed filing obligation.

  • Collect all 1099-DAs from custodial brokers. Clients who use multiple exchanges may receive multiple 1099-DAs. Ask about every exchange account, not just the one the client mentions first. Coinbase, Kraken, Gemini, and any other US-registered custodial broker with digital asset activity should be issuing a 1099-DA for 2026.
  • Check Box 9 on every 1099-DA line item. Box 9 checked = non-covered; you own the basis. Box 9 unchecked = covered; start with Box 1e and reconcile. This is the first step of preparation, not an afterthought.
  • Pull client-maintained basis records for all non-covered transactions. Exchange transaction history exports, purchase confirmations, cost-basis software output, bank records, and contemporaneous client records are all valid sources. Document what was used.
  • Reconcile broker basis (Box 1e) against client records for covered transactions. Accept Box 1e when it matches. When it conflicts, use the correct basis, note the adjustment in Form 8949 Column G, and document the reconciliation. A CP2000 notice on a covered-basis discrepancy is avoidable with a documented adjustment; see the CP2000 response workflow if a notice arrives.
  • Collect records for non-custodial wallet transactions. Exchange history exports, blockchain explorer records, and cost-basis software output for every wallet address the client uses. No 1099-DA will exist for these transactions; the practitioner supplies everything.
  • Identify stablecoin and specified NFT transactions; confirm broker election status. If a client transacted in stablecoins or specified NFTs and received no 1099-DA for those transactions, determine whether the broker made an optional reporting election under OBBBA. The absence of a form does not mean the transactions are non-taxable; they must be self-reported.
  • Check for cross-broker transfers that may have converted covered to non-covered at the receiving broker. An asset that was covered at the sending broker (post-2025 acquisition, custodial) may arrive at the receiving broker as non-covered if the acquisition date precedes January 1, 2026, or if the transfer originates from a non-custodial source.
  • For clients with pre-2026 holdings still unsold: document acquisition dates now. Assets acquired before January 1, 2026, are non-covered when sold regardless of when the sale occurs. If those assets are still in the client's portfolio at year-end 2026, document the acquisition dates while records are accessible, before data retention periods at older exchanges expire.
  • Screen for FBAR and international reporting obligations. Ask whether any digital assets are held on foreign exchanges or in foreign account structures. If yes, screen for FBAR (FinCEN Form 114), Form 8938, and potential PFIC obligations. Verify current thresholds at FinCEN.gov and IRS.gov. If accuracy-related penalties are a concern due to unreported prior-year digital assets, see the penalty abatement practitioner guide for the first-time abatement and reasonable cause pathways.
  • Report all dispositions on Form 8949 with the correct checkbox. Covered with matching basis: Box A (short-term) or Box D (long-term). Non-covered with self-reported basis: Box B (short-term) or Box E (long-term). No 1099-DA issued: Box C (short-term) or Box F (long-term). Do not aggregate covered and non-covered transactions in the same checkbox grouping.

IMPORTANT: THIS GUIDE IS INFORMATIONAL, NOT TAX ADVICE

Digital asset tax guidance is an area of active IRS regulatory development. All positions described in this guide must be verified at IRS.gov before applying to any specific client situation. The covered/non-covered definition, Form 1099-DA box structure, OBBBA stablecoin and NFT election provisions, wash sale rule applicability, and IRS matching program scope are all subject to additional IRS guidance that may refine or change the rules described here. This guide does not constitute tax advice for any specific client situation.

Regulated Claims and Verification Requirements

The following claims require verification before applying to any return: (1) Covered/non-covered transition date: reflects current IRS and broker guidance; additional IRS guidance may refine or extend these rules; verify at IRS.gov. (2) Form 1099-DA box structure: reflects the form as issued through 2026; verify against current IRS instructions at IRS.gov before filing. (3) OBBBA stablecoin and specified NFT optional reporting election: reflects OBBBA provisions and transitional guidance; verify current broker election status and IRS guidance at IRS.gov. (4) Wash sale inapplicability to digital assets: digital assets are currently classified as property, not subject to IRC 1091 as currently interpreted; IRS and Congress may extend wash sale rules; verify current law at IRS.gov. (5) On-chain rewards as covered assets: generally treated as covered when received in a custodial account on or after January 1, 2026; subject to additional IRS guidance; verify at IRS.gov. (6) FBAR threshold: verify the current threshold at FinCEN.gov; dollar amount intentionally omitted. (7) Hard fork treatment: verify against Rev. Rul. 2019-24 and current IRS.gov guidance. (8) IRS 1099-DA matching: IRS matching program operational scope subject to IRS administration; verify current activity at IRS.gov. (9) Form 8300 digital asset applicability: subject to FinCEN and IRS transitional guidance; verify at IRS.gov.

Frequently Asked Questions: 1099-DA Covered Basis Reporting for 2026

Will the IRS match 1099-DA covered-basis reporting against the taxpayer's Form 8949?

For covered transactions where the broker reports both gross proceeds (Box 1d) and cost basis (Box 1e), the IRS has the data to match those figures against the taxpayer's Form 8949 filing. Discrepancies between the broker-reported amounts and the return may trigger CP2000 automated underreporter notices. The IRS matching program's operational scope and timing are subject to IRS administration; verify current matching activity at IRS.gov. Practitioners should ensure that any adjustment to broker-reported basis is documented on Form 8949 with the appropriate reason code. If a CP2000 notice arrives for a 2026 digital asset transaction, see the CP2000 response workflow for the response process.

What if a client's actual basis is different from what Box 1e on the 1099-DA shows?

Use the correct basis. Report the adjustment on Form 8949, Column G, with the applicable reason code indicating the basis correction. Document the reconciliation in the client workpapers, including the source of the correct basis figure and why it differs from Box 1e. Common broker basis errors include missing transfer-in basis, incorrect lot identification, and failure to account for fees paid at acquisition. Do not accept a broker's Box 1e figure that you have verified is incorrect simply because it is what the broker reported; the return must reflect the correct taxable gain or loss.

Does the wash sale rule apply to digital assets reported on the 1099-DA?

As of 2026, IRC 1091 wash sale rules apply to stock and securities, not property. Digital assets are currently classified as property under IRS guidance, placing them outside the scope of IRC 1091 as currently interpreted. If Box 1g on a client's 1099-DA shows a wash sale loss disallowance, investigate the broker's methodology before accepting the adjustment; the broker may be applying the rule incorrectly. IRS and Congress may extend wash sale rules to digital assets; verify current law at IRS.gov before advising clients.

What if a client received digital assets from a hard fork or airdrop in a custodial account in 2026?

Hard fork and airdrop receipts in a custodial account are generally taxable as ordinary income at the fair market value on the date of receipt, establishing a basis equal to that FMV for any subsequent disposition. If the broker reported the receipt on a 1099-DA, the reported basis should reflect FMV at receipt. Because these assets were received in a custodial account on or after January 1, 2026, they are generally treated as covered, with basis equal to FMV at receipt. Verify treatment against Rev. Rul. 2019-24 and current IRS.gov guidance; subsequent IRS guidance may modify that treatment.

If a client has no 1099-DA for 2026, does that mean they have no reportable digital asset activity?

No. Non-custodial wallet transactions generate no Form 1099-DA regardless of transaction size or frequency. Stablecoin and specified NFT transactions may be excluded from 1099-DA if the broker made an optional reporting election under OBBBA. Broker errors and platform coverage gaps can also result in missing forms. The practitioner must ask about all digital asset activity regardless of what documents the client provides; the absence of a 1099-DA does not confirm the absence of taxable activity.

How does 1099-DA covered-basis reporting interact with digital asset Form 8300 reporting?

They are separate obligations. Form 1099-DA is an information return for digital asset dispositions filed by brokers. Form 8300 is filed by businesses that receive more than $10,000 in cash (or cash equivalents) in a single transaction or related transactions in the course of a trade or business. Whether digital assets constitute cash for Form 8300 purposes is subject to FinCEN and IRS transitional guidance; verify current applicability at IRS.gov and FinCEN.gov before advising clients who accept digital asset payments in their business. A client who receives digital assets as payment for business services may have both a 1099-DA (from their exchange when they sell) and a Form 8300 obligation (when they receive large payments) -- these are independent and neither satisfies the other.

1099-DA covered-basis reporting intersects with foreign account disclosure, penalty abatement, CP2000 response, and international investment structures. These guides cover the adjacent workflows:

Prepare for January 2027 Before the Filing Season Starts

The covered-basis 1099-DAs arrive in January 2027. Practitioners who understand the covered/non-covered framework now, who advise clients on recordkeeping through the rest of 2026, and who have a reconciliation workflow ready before year-end will handle 2026 digital asset returns efficiently. Those who encounter this framework for the first time in filing season will not. America's Tax Professionals has supported independent EROs and small firms through every major filing season change since 2001. Contact us to learn how our resources, software, and practitioner tools support accurate digital asset return preparation.

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