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Tax Strategy: Developments in the taxation of digital assets

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The taxation of digital assets continues to be an area of confusion. The Internal Revenue Service has long taken the position that digital assets are treated the same as other property and are taxed when you receive them as payment for a transaction or where you sell them or trade them in a transaction. Like other property, digital assets are not taxed when you receive them for cash.

However, issues have come up when digital assets are received for other purposes, such as through forks, mining or staking — transactions involving digital assets which as capital assets would be reported on Form 8949.

The recent focus by the IRS has been on broker reporting of digital asset transactions to try to reduce noncompliance in the area. The Infrastructure Investment and Jobs Act authorized the broker reporting of digital assets. Form 1099-B, the existing broker reporting form, was initially used for the reporting requirement. Questions arose, however, as to who is a broker in the digital assets context and whether the entities that the IRS designated as digital asset brokers have the information to make the required reports to the IRS.

The IRS has now developed Form 1099-DA for digital assets. Final regulations on broker reporting were issued on June 28, 2024. The service is hoping to be able to match Form 1099-DA reports from brokers to Form 8949 reports from taxpayers.

Form 1040 reporting

For 2024 tax returns, the digital asset question on the Form 1040 has not changed from 2023: “At any time during 2024, did you: (a) receive (as a reward, award or payment for property or services); or (b) sell, exchange or otherwise dispose of a digital asset (or a financial interest in a digital asset)?”

There are disputes between the IRS and the crypto industry about when crypto is converted into something else. For example, there is currently litigation over whether rewards of additional crypto for staking — the process of locking up your cryptocurrency in a wallet to help run a blockchain — results in a taxable transaction (the view of the IRS if the taxpayer has the ability to sell, exchange or otherwise dispose of the rewards) or a nontaxable transaction (the Jarrett cases).

In Revenue Ruling 2023-14, the IRS reaffirmed its position that staking rewards are taxable. The IRS issued a refund in the first Jarrett case to get a court decision that the issue was moot and no decision on the merits was made. In Rev. Rul. 2023-14, the IRS did not provide any guidance as to how staking awards should be valued. It also stated that it was taking no position at the time as to whether “gas” fees paid to a validator for the cost of the computing power used in the validation process are taxable.

Since digital assets are not viewed by the IRS as securities, the wash sale rules do not apply to digital asset transactions. Digital assets treated as capital assets qualify, along with other capital assets, for tax loss harvesting.

Broker reporting

The issues that have come up with broker reporting of digital asset transactions include who is a broker; getting the brokers to report not only the values of digital assets at the time of the transaction but also the cost basis of those assets; helping broker reporting match taxpayer reporting; and determining what information is available to the brokers to comply with filing the Form 1099-DA.

The final version of the 2025 1099-DA was issued on Jan. 10, 2025. It is to be used for 2025 transactions and issued by Feb. 17, 2026 (electronically by March 31, 2026). The instructions discuss reporting of when the broker is using customer-provided information (Box 8), dates of transfer (Box 12b), and reporting of nonfungible tokens and stable coins.

To assist traditional brokers who only have limited involvement with digital assets, Form 1099-B may still be used for tokenized securities settled or cleared on a limited-access regulated network. To assist brokers in transitioning to the new reporting requirements, the IRS is deferring broker reporting of the cash basis on digital assets until 2026. The IRS is also planning to require that, in determining the digital assets to look at for the cost basis, the taxpayer look only to the particular wallet or account held by the broker, again so that the 1099-DA information is more likely to match the information on the tax return.

Crypto tax

There are issues with calculating the crypto cost basis to apply. Taxpayers would generally prefer to apply specific identification by the taxpayer so that the taxpayer can select the highest-basis crypto that is being sold. The IRS wants the broker custodian of the crypto and even trading front-end service providers (DeFi brokers) to report the cost basis on Form 1099-DA.

The service is also proposing that, to help the crypto broker reporting on Form 1099-DA match what the taxpayer is reporting on the tax return, the cost basis be determined separately for each wallet, rather than being able to combine all similar crypto held in separate wallets. For 2025, Form 1099-DA is being required to be filed by crypto brokers; however, the cost basis is not being required. Litigation is also challenging the application of the broker reporting requirements to DeFi brokers.

Revenue Procedure 2024-28 provides a safe harbor under Code Sec. 1012(c)(1) to allocate unused basis of digital assets held within each wallet or account of the taxpayer as of Jan. 1, 2025. The default allocation of basis is based on first-in/first-out principles; however, the taxpayer or the broker, as directed by the taxpayer, may utilize specific identification. The deadline for making the allocation is the earlier of the date of the first sale in the year or the due date for the 2025 tax return. Frequently asked questions provide guidance as to when specific identification can be used.

Notice 2024-56 provides transitional relief to brokers who fail to report sales of digital assets or fail to do back-up withholding. It also permits brokers to rely on uncertified taxpayer identification numbers for 2026. Several types of transactions are specifically excluded from broker reporting requirements. Notice 2024-57 provides related penalty relief for brokers’ failure to file information returns.

To help crypto brokers get their technology together to do cost-basis reporting, the IRS has delayed the crypto cost-basis reporting requirement until after Dec. 31, 2025. This permits taxpayers to continue to use specific identification for crypto transactions based on the taxpayer’s books and records rather than the broker’s 1099-DA report for 2025. FIFO remains the default treatment for 2025 if the taxpayer does not do specific identification.

Summary

The IRS is still struggling to keep up with all the forms of digital asset transactions as they are developed. It is also struggling to get effective third-party reporting by brokers in order to reduce taxpayer noncompliance. In the meantime, the crypto industry hopes that the Trump administration might have a friendlier tax view of crypto transactions, and the IRS focus might change under new leadership.

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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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