The Digital Chamber (TDC) welcomes the IRS’s release of final regulations on digital asset reporting requirements. We are encouraged by the IRS’s responsiveness to public comments and their adoption of a phased implementation approach, which demonstrates a commitment to balancing regulatory needs with industry concerns. 

We applaud several key improvements in the final regulations: 

  1. Custodial Focus: The IRS has wisely narrowed the initial focus to custodial brokers, allowing more time to address the complexities of non-custodial and decentralized platforms. 
  1. Stablecoins: We appreciate the introduction of a $10,000 annual de minimis threshold for qualifying stablecoin sales and the option for aggregate reporting above this threshold. This approach significantly reduces unnecessary reporting burdens for many users. 
  1. NFTs: The adoption of a $600 annual de minimis threshold for NFT sales and the option for aggregate reporting above this amount shows recognition of the unique nature of these assets. This aligns more closely with our recommendation for a nuanced approach to NFT reporting. 
  1. Transaction Reporting: We are pleased that brokers will not be required to report wallet addresses and transaction IDs to the IRS, addressing some of our privacy concerns. 

While these changes represent significant progress, we believe there are still areas for further refinement: 

  1. Digital Asset Middlemen: The definition remains broad, and we continue to advocate for a narrower focus on entities directly facilitating digital asset sales and exchanges. 
  1. Future Guidance: As the IRS develops rules for non-custodial and decentralized platforms, we urge continued engagement with industry stakeholders to ensure practical and innovation-friendly approaches. 

TDC remains committed to working collaboratively with regulators to develop balanced approaches that promote tax compliance while fostering growth and innovation in the digital asset ecosystem. We look forward to ongoing dialogue as these regulations are implemented and future guidance is developed. 

For reference, please see TDC’s comments to the proposed rules from November 2023.  

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