Form 1099-DA: A Tax Preparation Checklist for RIAs
Published September 21, 2026
Introduction
A client may hold cryptocurrency on an exchange, keep older assets in a personal wallet, and move funds between platforms throughout the year. Their advisor sees part of that activity. Their CPA may see another part when tax documents arrive.
Form 1099-DA adds a reporting document to that picture, but it does not necessarily bring all the records together. Missing purchase history and transfers between accounts can still leave questions about what the client sold and what it originally cost.
For RIAs preparing for year-end conversations, now is a useful time to identify those gaps. Helping clients organize their records in the fall gives their tax professional more time to resolve questions before the 2027 filing season.
What changes for Form 1099-DA in 2026?
Form 1099-DA is the information return brokers use to report certain digital-asset sales and dispositions to customers and the IRS. Two reporting years matter here.
- 2025 transactions, reported in 2026: The first reporting year focused on gross proceeds. The IRS noted that most statements for 2025 transactions would not include cost basis.
- 2026 transactions, reported in 2027: Brokers must also report basis for covered digital assets, subject to applicable exceptions. The 2026 Form 1099-DA instructions distinguish covered assets from noncovered assets, for which basis reporting generally remains optional.
Covered assets generally must have been acquired after 2025 in the reporting broker’s custodial account and remained there until disposition. Assets acquired before 2026 or transferred into the broker are generally noncovered. Special reporting methods can also omit basis for certain stablecoin and NFT transactions.
That distinction matters when setting client expectations. Next year’s statement may contain more information without providing everything needed to prepare the return.
Why missing cost basis deserves attention now
Gross proceeds describe the amount received from a sale. They do not, by themselves, establish the taxable gain.
Consider a simplified example: a client bought a digital asset for $12,000, later moved it to another platform, and sold it for $18,000. Ignoring fees and other adjustments, the gain would be $6,000. If the receiving platform’s statement omits basis, the purchase record is still needed to support that calculation.
A blank basis field does not establish a zero-dollar basis. It signals that the preparer needs additional information.
There is also a limit to what sending purchase records to a broker can accomplish. The IRS explains that brokers may use reliable customer-provided acquisition information for lot ordering, but cannot rely on it to report basis for transferred-in assets.
For the advisor, the useful question is straightforward: does the client still have the records showing when and how the assets were acquired?
What records should RIAs help clients gather?
Start with an inventory of the exchanges, custodial accounts, and personal wallets the client used. Include accounts that were closed or emptied during the year.
Then coordinate with the client’s tax professional on a document request. A practical starting list includes:
- Transaction exports showing purchases, sales, and exchanges
- Original acquisition records for assets sold, including purchases from earlier years
- Dates, quantities, U.S. dollar values, and transaction fees
- Transfer records connecting activity between the client’s accounts or wallets
- Records of staking rewards, mining income, or payments received in digital assets for separate tax review
- Prior-year tax workpapers and any existing basis reconciliations
- Forms 1099-DA and other relevant tax statements when available
Ask for available records now, then refresh them after year-end. Keep original exports alongside any summaries so the preparer can trace discrepancies back to the underlying activity.
Use the firm’s approved secure document-sharing process. Record collection should never require a client’s wallet seed phrase or private keys.
Separate transfers from sales and other activity
A withdrawal from one platform and a deposit into another need to be understood together. Without that connection, an imported transaction history may be incomplete or misleading.
The IRS distinguishes transfers between wallets or accounts the taxpayer owns from disposals, while noting that fees paid with digital assets require separate attention.
Ask the client to identify the sending and receiving accounts and provide available transaction references. The tax professional can then evaluate the transfer and any associated fees.
Avoid asking clients to label every unfamiliar transaction themselves. A short list of unresolved items, with supporting records, gives the preparer a better starting point than guesses embedded in a spreadsheet.
Do not use Form 1099-DA as the complete activity record
Some clients may assume that a transaction does not need attention if no tax statement arrives. The IRS makes clear that digital-asset income, gains, and losses must be reported whether or not the taxpayer receives Form 1099-DA.
Ask about activity beyond the accounts that issued statements, including personal wallets, overseas platforms, and rewards. Let the tax professional determine the reporting treatment.
When statements arrive, compare them with the records already collected. If a form contains incorrect information, the IRS directs taxpayers to request a corrected Form 1099-DA from the issuer and retain the related correspondence.
An omitted basis field on a noncovered transaction is not necessarily an issuer error. Separate missing supporting records from information that actually needs correction.
Make the advisor and CPA handoff specific
An RIA can help organize the information within its engagement scope while the tax professional handles basis determinations, transaction classification, and return preparation.
With the client’s authorization, agree on who will collect missing documents, who will resolve technical questions, and when the advisor can expect updated tax figures for planning. Keep uncertain amounts clearly marked so a preliminary estimate does not become an assumed fact in a year-end projection.
SAM’s article on tax planning as a value-added service for RIAs discusses this broader coordination role. SAM’s support for RIAs connects tax expertise and advisory workflows, giving firms a way to bring tax professionals into relevant client conversations.
For digital-asset work, confirm the assigned professional’s experience and the scope of any reconciliation needed before setting expectations with the client.
Conclusion
Use the next client review to ask where digital assets are held, whether assets moved between platforms, and whether the original purchase records are available.
A short, targeted document request now can reveal which clients need more help before year-end. When Form 1099-DA arrives, the advisor, client, and tax professional will have a clearer record to work from.
