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How Form 1099-DA is impacting state-level reporting

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The regulatory environment for digital assets will have significant implications for state-level reporting requirements. A notable development is Montana’s introduction of the Form 1099-DA mandate, reflecting a broader trend toward increased oversight of digital asset transactions. 

This article provides an overview of the current and expanding 1099-DA state reporting landscape and delves into Montana’s specific requirements. I’ll discuss the limitations of relying solely on combined federal/state filing programs for compliance and outline the key steps that crypto brokers and tax professionals should take to ensure adherence and avoid penalties in 2025.

As digital assets like cryptocurrencies and non-fungible tokens become more prevalent, tax authorities are implementing measures to ensure proper reporting and taxation. The Internal Revenue Service has introduced Form 1099-DA, officially titled “Digital Asset Proceeds from Broker Transactions,” to standardize the reporting of digital asset transactions. This form is designed to capture detailed information about digital asset sales and exchanges, including acquisition dates, cost basis, sale dates and proceeds. The goal is to enhance tax compliance and provide clarity for taxpayers involved in digital asset transactions. 

While the IRS has established federal reporting requirements, individual states are also enacting their own mandates to ensure accurate tax reporting within their jurisdictions. These state-level requirements often complement federal regulations but typically include additional stipulations unique to each state. For instance, some states may require direct submission of forms through state-specific portals, bypassing traditional federal-state combined filing programs.

Montana’s unique 1099-DA reporting requirements

Montana has taken a proactive approach by introducing specific reporting requirements for digital asset transactions (effective with 2025 transactions) in its 2024 Employer and Information Agent Guide. The Montana Department of Revenue mandates that businesses and brokers involved in digital asset transactions submit Form 1099-DA directly through the state’s TransAction Portal. This requirement is distinct from the federal filing process and emphasizes the state’s commitment to accurate and timely reporting of digital asset activities. 

The Combined Federal/State Filing program allows businesses to file certain information returns with the IRS, which then forwards the data to participating states. While this CF/SF program streamlines the reporting process for various forms, it may not fully accommodate the specific requirements that states like Montana have implemented for digital asset transactions.

Montana’s insistence on direct submission through its TAP system of all information returns required to be filed with the state, underscores the limitations of relying solely on the CF/SF program for compliance. The state’s unique reporting mandates mean that businesses cannot depend exclusively on federal filings to meet state obligations. Failure to adhere to Montana’s specific submission protocols could result in non-compliance, leading to potential penalties and increased scrutiny from state tax authorities.

Key steps for crypto brokers and tax professionals to ensure compliance

To navigate the evolving regulatory landscape and ensure compliance with both federal and state reporting requirements, crypto brokers and tax professionals should consider the following steps:

  1. Stay informed about regulatory changes: Regularly monitor updates from the IRS and state tax authorities regarding digital asset reporting requirements. Subscribe to official newsletters, attend webinars and consult with professional organizations to stay abreast of any changes.
  2. Understand state-specific mandates: Familiarize yourself with the unique reporting requirements of each state in which you operate. For Montana, this includes understanding the TAP system and the specific protocols for submitting Form 1099-DA.
  3. Utilize approved software for reporting: Ensure your reporting software is approved by the Montana Department of Revenue for bulk file submissions. This may involve annual registration and testing to confirm compatibility with the state’s systems.
  4. Implement robust record-keeping practices: Maintain detailed records of all digital asset transactions, including dates, amounts, asset types and parties involved. Accurate record-keeping is essential for compliance and can aid in the event of an audit.
  5. Provide accurate and timely information to clients: Educate clients about their tax obligations related to digital assets and ensure they receive the necessary forms and information in a timely manner. This includes furnishing copies of Form 1099-DA to clients as required.
  6. Consult with tax professionals: Given the complexity of digital asset taxation, clients should consider consulting with tax professionals who specialize in this area. They can provide guidance tailored to the client’s specific circumstances and help ensure compliance with all applicable regulations.
  7. Prepare for potential audits: Develop internal protocols to respond to potential audits or inquiries from tax authorities. This includes having readily accessible records and a clear understanding of the reporting processes you have implemented.

What are the key challenges and benefits of this new reporting requirement?

As with any new significant tax law or standard that is introduced, its implications can be far-reaching and impact several parties albeit differently based upon the role they play in the process. Here are the expected impacts for the key stakeholders in the implementation of Form 1099-DA. 

For taxpayers

Transparency and simplicity

  • Clear record of transactions: The 1099-DA provides a clear record of transactions, eliminating the need for taxpayers to manually compile data from various exchanges.
  • Simplified tax reporting: This form simplifies the process of identifying buy and sell transactions, fees and basis, making income tax reporting more straightforward.

Demand for tax information

  • Standardized form: Taxpayers have long requested a standardized form to streamline their income tax reporting process. The 1099-DA answers this call, reducing the confusion and effort involved in reporting crypto transactions.

For the IRS

Enhanced compliance

  • Third-party reporting: The 1099-DA is a crucial tool for the IRS to enforce income tax compliance by matching reported income with 1099-DA data.
  • Accurate tax assessment: This helps the IRS more accurately assess tax liabilities and close the tax gap.

Regulatory efforts

  • Regulating the crypto industry: The introduction of the 1099-DA is a significant step in the IRS’s efforts to regulate the crypto industry and gather necessary data to enforce tax laws effectively.

For brokers

Customer service experience

  • Optimized tax documents: Providing specialized tax documents helps brokers meet their clients’ tax reporting needs and enhances their financial service offerings.

Risk and liability management

  • Compliance benefits: Adhering to 1099-DA reporting requirements helps brokers minimize the risk of audits and penalties, ensuring they remain in compliance with tax regulations while avoiding potential fines and legal complications.

By proactively addressing these areas, crypto brokers and tax professionals can navigate the complexities of digital asset reporting and minimize the risk of noncompliance. As regulations continue to evolve, staying informed and adaptable will be key to maintaining compliance and avoiding potential penalties in 2025 and beyond.

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Accounting

SEC’s Semiannual Reporting Proposal Faces Investor Pushback: What CFOs Need to Know

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U.S. Securities and Exchange Commission (SEC)

A proposal from the U.S. Securities and Exchange Commission to potentially shift some public companies away from quarterly financial reporting toward a semiannual model is drawing significant pushback from investors, even as it continues moving through the regulatory process. The debate has direct implications for corporate finance teams, auditors, and the broader transparency of U.S. capital markets.

What the SEC Proposed

According to a summary published by accounting advisory firm Cohen & Co., the SEC issued a proposed rule on May 19, 2026, aimed at simplifying financial reporting requirements for many U.S. public companies. The proposal would potentially reduce the frequency of certain mandatory disclosures from quarterly to semiannual, a structural change that has not been made to core U.S. reporting requirements in decades.

The proposal follows an extended debate within U.S. policy circles, with proponents arguing that reduced reporting frequency could lower compliance costs and free up management time for longer-term strategic planning rather than quarter-to-quarter results management.

Why Investors Are Pushing Back

Comment letters submitted in response to the proposal have been extensive, and according to Cohen & Co.’s review of the public record, investors “appear to be largely opposed” to the shift, viewing frequent interim reporting as a core benefit of U.S. capital markets relative to other jurisdictions.

Accounting and law firms have taken a more measured position, generally urging any changes to remain aligned with the Financial Accounting Standards Board (FASB), whose existing disclosure requirements and guidance are built around a quarterly reporting cadence. A shift to semiannual reporting without corresponding changes to FASB guidance could create friction between SEC filing requirements and GAAP-based disclosure expectations.

Lessons From the U.K. Experience

The debate is not without precedent. The United Kingdom moved away from mandatory quarterly reporting for listed companies in 2014, returning to a semiannual disclosure requirement. According to Cohen & Co.’s analysis, that experience offers a cautionary data point: there was no measurable increase in capital expenditure or R&D investment following the change, while analyst coverage of affected companies declined as reliable interim information became less available — a particular risk for smaller and newly public companies that rely on analyst coverage to maintain investor visibility.

Practical Implications for Finance Teams

Beyond the debate over disclosure philosophy, the proposal carries practical complications. Many companies have debt covenants and credit agreements structured around quarterly financial delivery; a shift to semiannual reporting could require renegotiating those terms. Reduced reporting frequency would also extend the “window of market silence” between disclosures, a factor that governance and investor-relations teams would need to manage carefully to avoid information asymmetry.

Separately, and unrelated to the reporting-frequency debate, the SEC and FASB have continued finalizing more routine updates this year. New Accounting Standards Updates are taking effect for December 31, 2026, fiscal year-ends covering income tax disclosures, credit loss measurement, induced debt conversions, and stock compensation, according to Eide Bailly’s review of 2026 ASU activity. Additional guidance on paid-in-kind dividends and environmental credits is also on the near-term horizon.

What to Watch Next

The semiannual reporting proposal remains in the comment and review phase, and no final rule has been adopted as of this writing. Finance leaders should monitor the SEC’s regulatory agenda for further movement, while treating the current quarterly reporting requirement as the operative standard until any final rule is issued and an effective date is set.

Given the extent of investor opposition documented in the comment file, a full shift to mandatory semiannual reporting appears more likely to result in either a scaled-back compromise or continued study rather than swift adoption — though the SEC’s ultimate direction remains uncertain.

 

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Accounting

AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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