Form 1099-DA Readiness

What Form 1099-DA is

Form 1099-DA is the IRS's information-reporting form for digital asset transactions. Brokers report digital asset dispositions on it beginning with the 2025 tax year, on forms issued in early 2026.

It implements IRC §6045, which has long required brokers to report proceeds from securities sales to both the IRS and the customer. The final custodial-broker regulations — T.D. 10000, published July 9, 2024 — extended that requirement to digital assets.

Where the rules stand for non-custodial participants

This history is unusually eventful, and it is worth stating precisely rather than summarising:

• T.D. 10000 (July 9, 2024) finalised the custodial-broker rules and reserved the definition of "digital asset middleman" as it would apply to non-custodial participants — leaving that question open rather than answering it.
• T.D. 10021 (December 30, 2024) then reached non-custodial front-end service providers.
• Public Law 119-5 (April 10, 2025), a Congressional Review Act joint resolution, nullified T.D. 10021 before it took effect. T.D. 10000 was left intact.

How that history applies to any particular validator operator, staking arrangement, or software provider is a legal question with genuine open edges — and it is a question about your facts, not ours.

TrueStake does not publish a position on it. Our own counsel review of this topic is open and unresolved, and we would rather tell you that than hand you a confident answer you cannot rely on. Ask your tax professional what the current rules mean for your circumstances.

What TrueStake does

TrueStake issues no tax forms of any kind — not Form 1099-DA, not any other information return, for any customer. What it produces is the record underneath: every reward event derived from consensus data, reconciled against the actual on-chain receipts to the wei, with a citation for each figure.

The recognition obligation is independent of the form

This part is settled, and for planning purposes it is the part that matters most. Under Rev. Rul. 2023-14, staking rewards are includible in gross income when the taxpayer gains dominion and control over them. That obligation stands on its own: an information return's presence or absence changes neither the amount nor the timing of the income.

What an information return does change is filing mechanics. The 2025 Form 8949 instructions direct digital-asset dispositions to different boxes depending on whether a 1099-DA was issued for that transaction — a reporting-path difference, not an income-recognition one.

TrueStake's export is designed to function as your own audit-quality record of self-reported staking income.

Not tax advice. Consult a qualified tax professional regarding your specific circumstances.