The Missing Pipe

When you sell a stock, your broker knows what you paid. It knows because your old broker sent a transfer statement. That statement carries your cost basis from one firm to the next. Congress built this pipe in 2008. It started flowing in 2011. Every stock broker in the country uses it.

Crypto just got its own reporting form. The 1099-DA. Coinbase, Kraken, Crypto.com all filed them for the first time this year. The IRS can now see every dollar you sell.

The pipe that carries what you paid? Not attached.

What the Form Does

For 2025, brokers report one thing: gross proceeds. What came out. Every sale. Every swap. Every conversion. The IRS gets a copy. You get a copy.

What went in? Your cost. What you paid for the coin. Blank. Not required until 2026 transactions. And even then, the rules have a gap so wide the IRS itself could fall through it.

The Break

Starting in 2026, brokers must report cost basis. But only for coins you bought and sold at the same broker. The moment you move a coin to a different exchange, the receiving broker must treat it as noncovered. Blank basis. Even if you hand them a receipt. Even if they can see what you paid on the blockchain.

Look. This isn’t a guess. The statute says so. Section 6045(g) does not require a broker to report basis on a noncovered asset. The broker’s hands are tied by the same law that created the form.

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Stocks Fixed This Fifteen Years Ago

Section 6045A. Transfer statements. When you move shares from Schwab to Fidelity, Schwab sends Fidelity a file that says: “This client bought 100 shares of XYZ on March 3rd at $40.” Fidelity picks up where Schwab left off. The basis chain stays whole.

Treasury said they’d write the same rules for crypto. Here’s what the preamble to the final regs actually says:

The details of how section 6045A reporting will apply to brokers of digital assets will not be addressed until a future notice of proposed rulemaking.

No date. No draft. No timeline.

Sure.

Five Cents on the Dollar

Deloitte’s Jonathan Cutler put the number at 5%. Five percent of a customer’s transactions will qualify as “covered” in the first year of basis reporting. That means ninety-five cents of every dollar you sell could show zero cost on the form the IRS receives.

I mean. Think about that number at scale. Every person who ever moved Bitcoin off Coinbase. Every person who swapped exchanges for better fees and sent coins back again. All noncovered. All blank basis on the government’s copy.

The Machine

Here’s where the pipe matters.

The IRS runs a program called the Automated Underreporter. It’s a computer. It takes your 1099-DA. It takes your tax return. It compares them.

The form says $100,000 in proceeds. The form says blank basis. The computer does the math. $100,000 in gain. It doesn’t call you. It doesn’t check. It mails a CP2000 notice. Proposed tax on the full amount. Twenty percent penalty. Thirty days to respond.

Don’t respond? The computer converts the proposal into an assessment. On its own. No human reviews the file. The penalty becomes real. The collections process starts.

Your actual gain was $20,000. The machine billed you on $100,000. The difference is your problem to prove.

The Kicker

You’d think there’s some protection here. There is. Sort of.

The IRS has announced in Notice 2024-56 that it will not impose penalties on brokers who make good faith efforts to comply with 1099-DA filing for 2025 transactions, even if forms contain errors.

Right. Brokers get good-faith relief. Not you. The broker files a form with a blank where your cost should be. The broker is protected. You get the CP2000.

The pipe exists for stocks. Has for fifteen years. For crypto, they said they’d build it later. The machine didn’t wait.