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IRS releases FAQs on crypto broker reporting

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The Internal Revenue Service has posted guidance in the form of questions and answers on digital asset broker reporting on the new Form 1099-DA.

The requirement for companies to report on crypto transactions emerged under the Infrastructure Investment and Jobs Act of 2021. It classifies crypto exchanges and trading platforms as brokers and requires them to report on their customer’s gains and losses to the IRS every year starting with tax year 2025. Customers and the IRS are supposed to start receiving the forms in time for the 2026 tax season.  The Treasury and the IRS issued final regulations on the reporting, which is required to be made on Form 1099-DA, beginning with transactions on or after Jan. 1, 2025.

The FAQ page, posted last week on IRS.gov, explains the rules for a number of different scenarios, such as digital asset kiosks and terminals, custodial digital asset brokers, and businesses that provide custodial services to large digital asset institutions and investors, but don’t execute sales transactions themselves.

“Several questions address the treatment in some cases of transfers and transactions based on customer-provided acquisition information and provide additional instructions on how to fill Form 1099-DA in those scenarios,” said Tomer Siegal, vice president of product at the Ledgible, a provider of crypto tax and accounting software, in a LinkedIn post.

He noted that the FAQs also provide more examples and clarifications on the allocation and treatment of transaction fees in various scenarios. “The FAQs affirm that digital asset kiosks that effect sales of digital assets are digital asset middlemen, subject to the section 6045 reporting obligations, and must file a Form 1099-DA,” he wrote. “A business that only provides custodial services and transfers assets to an exchange (without effecting the sale itself) generally does not have a reporting obligation. A custodial broker is permitted (but not required) to use “reasonably reliable” acquisition information, such as statements from a transferring custodial broker, to determine lot ordering for a sale. However, this information generally cannot be used to report the basis on Form 1099-DA.”

The FAQ also acknowledges a mistake in the 2025 Form 1099-DA, Siegal pointed out, where it incorrectly states that the gross proceeds for sales of nonfungible tokens where there are gross proceeds attributable to first sales by the creator or minter of the NFT should be reflected in Box 1f (Proceeds) and Box 11c (aggregate reporting of specified NFTs attributed to 1st sale by minter). The IRS only wants you to report the gross proceeds in Box 11c and to leave Box 1f blank. The FAQs also confirm that for testing whether a qualifying stablecoin has “de-pegged” (that is, deviated significantly from the value of its reference asset), a broker only needs to consider if the stablecoin de-pegged on its own trading platform.

“A number of FAQs address brokers accepting ‘customer provided acquisition information’ (CPAI) for purposes of ordering the correct cost basis lot disposals,” wrote Jessalyn Dean, senior policy advisor of U.S. tax reporting for Ledgible, in a separate LinkedIn post. “But they use a very unlikely example of the transferring broker sending purchase confirmations (e.g. PDFs). I wish they had given clarity instead with the more realistic example of a taxpayer wanting to link up their retail crypto tax aggregator software. Brokers are not going to be ‘sending purchase confirms’ to each other.”

Some of the FAQs deal with specific checkboxes on Form 1099-DA. “Q4, Q5, and Q6 confirm that Box 8 (check if broker relied on CPAI) will be checked in perpetuity for all sales/exchanges until all assets in the account are sold, even if that specific sale/exchange was not ‘impacted’ by the reliance on CPAI,” Dean wrote. “Q9 highlights that there is a mistake in the 2025 Form 1099-DA instructions for sales of NFTs where there are gross proceeds attributable to first sales by the creator or minter. The instructions incorrectly state that both Box 1f (Proceeds) and 11c should be completed. It turns out that the IRS only wants you to report the gross proceeds in Box 11c and to leave Box 1f (Proceeds) blank. This will surely cause confusion.”

The de-pegging can apply across different crypto companies. “Q14 confirms that for testing whether a Qualifying Stablecoin has de-pegged during the 10-day measurement period, a broker only needs to consider if the stablecoin de-pegged on its own trading platform,” said Dean. “So Coinbase will not need to know if USDC has de-pegged on Binance in order to classify the asset as a Qualifying Stablecoin in their own (Coinbase) Form 1099-DA reporting.”

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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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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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