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The changing crypto landscape brings new risks to accounting

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The Internal Revenue Service’s new regulations and pro-crypto President Donald Trump’s return to office introduce fresh changes for accountants in 2025. At what point, many experts wonder, could the cost of dealing with digital assets outweigh the benefits?

Trump has expressed his support of the crypto industry since mid-2024. His actions include the creation of decentralized finance firm World Liberty Finance in a joint venture with his sons, Eric Trump and Donald Trump Jr., and proposals to create a strategic U.S. government reserve of bitcoin.

“We’re going to do something great with crypto,” Trump said in a December interview with CNBC’s Jim Cramer. “Because we don’t want China — and not just China, others are embracing it — and we want to be the head.”

Trump has even launched his own meme coin, “$TRUMP“, which hit the market on Jan. 17 at around $7 per coin and soared to a value of roughly $75 per coin on Jan. 19 and a market cap of $7.6 billion on Jan. 23, according to data from CoinMarketCap. First Lady Melania Trump also launched her own meme coin on Jan. 19, simply named “MELANIA,” which similarly started out around $7 per coin but now trades around $4 per coin as of Jan. 23.

Industry experts were fairly convinced prior to the mintings that the Trump administration would usher in a more crypto-friendly regulatory environment, and are now more certain of their predictions.

Justin Wilcox, tax and advisory services partner and cryptocurrency practice lead at Connecticut-based accounting firm Fiondella, Milone & LaSaracina LLP, said the coins “signal a crypto-friendly administration versus the prior four years under Biden and [former Securities and Exchange Commission Chair] Gary Gensler.”

“The SEC under the Trump presidency is already establishing a crypto task force, which will focus on a regulatory framework for digital assets,” Wilcox said. “This framework will hopefully result in clear guidelines for founders of cryptocurrencies to understand the relevant legal implications ahead of time.”

Expectations also include “legislation [that] may be pushed forward to establish a ‘strategic reserve’ for bitcoin and potentially other digital assets,” he said.

Read more: Trump names Uyeda acting chair of SEC

Regulators with the IRS have already put new accounting standards into place this year, featuring a new 1099-DA form and the end of “universal wallet accounting.”

Both of these changes increase the information lift required by brokers, taxpayers, banks and other parties (those working for decentralized finance organizations have another two years until they also need to comply with the IRS’s new requirements) reporting crypto transactions and holdings. It’s left many skeptical of how accurate filings will be at the start.

Digital asset companies such as the accounting solutions provider TaxBit and tax platform Ledgible have already begun incorporating new features or products into their offerings to account for standard changes from the IRS and the Financial Accounting Standards Board.

Ledgible’s Digital Asset Assessment program will help clients determine if their existing compliance, data and reporting infrastructure is up to par with current requirements. TaxBit’s Principal Market Analysis tool allows companies to use specific policy elections when determining their principal market in the valuation of digital assets.

“The DeFi tax reporting regulations will be challenging to brokers and taxpayers as the DeFi systems and protocols are not centrally governed,” Kell Canty, chief executive of Ledgible, said. “Self-calculating the true cost basis and calculations throughout various aspects of DeFi will be very challenging to taxpayers when it comes to calculating gains and losses. … For these DeFi brokers, the challenge is in collecting personal tax information from their users.”

Read more: New crypto regs will generate information deluge

While many of Trump’s legislative crypto efforts are still in their infancy, CPAs and other professionals are working to adapt for the 2025 tax year and beyond.

Chad Cummings, chief executive of Naples, Florida-based law firm Cummings & Cummings Law, said challenges abound for taxpayers and accountants who have to now account for audit risks, fair market value determinations, basic transaction calculations and more.

“For CPAs, this means greater demand for advisory services related to tracking and reconciling crypto transactions, implementing portfolio tracking systems and preparing for potential disputes with tax authorities,” Cummings said. “However, firms that fail to invest in staff training or crypto-specific technology risk reputational and financial exposure.”

Learn more about some of the top digital asset developments across the accounting profession in the last few months and what experts are doing to stay ahead of the curve.

AICPA building in Durham, N.C.

AICPA revises educational material on digital assets

Leaders of the American Institute of CPAs updated its practice aid for learning more about accounting for and auditing digital assets in January, following updated standards out of the Financial Accounting Standards Board.

The revised practice aid, which was developed using the notes of members from the AICPA’s Digital Assets Working Group, now includes a modernized definition of digital assets, new terms and questions such as, “Are nonfungible tokens in the scope of FASB ASC 350-60?” and “Are ‘wrapped tokens’ in the scope of FASB ASC 350-60?”

Updates include the removal of the term “crypto assets” in favor of new nomenclature like crypto intangible assets, in-scope crypto intangibles assets and out-of-scope crypto intangibles assets.

Read more: AICPA updates digital assets practice aid

Bitcoins

What a bitcoin reserve means for the accounting profession

With the naming of venture capitalist and former PayPal chief operating officer David Sacks as the White House’s AI and crypto “czar” and the Securities and Exchange Commission’s appointment of “Crypto Mom” Commissioner Hester Peirce to head up its cryptocurrency-focused task force, accountants are forecasting a high chance of bitcoin policy moves on the horizon.

In speaking with AT, experts with the Wall Street Blockchain Alliance say these appointments, in addition to controversial proposals to institute bitcoin reserves by President Trump and state changemakers, create an optimal regulatory environment for making the concept a reality — but risks will remain.

“Bitcoin’s price volatility itself poses a significant risk. … Large-scale government investments could lead to substantial fluctuations in reserve valuations, potentially impacting overall financial stability,” Sean Stein Smith, member of the alliance’s advisory board, and Ron Quaranta, chairman and chief executive of the alliance, said.

Read more: The accounting implications of a Bitcoin reserve

The IRS headquarters in Washington

New IRS rules for DeFI tax reporting take effect

Capping off 2024, the Internal Revenue Service issued its final regulations requiring decentralized finance brokers to record the sales and transactions of digital assets on its Form 1099-DA, as well as added support for those struggling during the transition period.

While DeFi brokers have a two-year buffer until the Jan 1. 2027, start date, centralized exchanges and platforms such as brokers, traders, banks and taxpayers must abide by the new rules as of Jan. 1, 2025.

“Although the applicability date proposed by the proposed regulations applied to gross proceeds reporting for sales of digital assets effected on or after Jan. 1, 2025, the Treasury Department and the IRS agree that a delay is warranted for trading frontend service providers treated as brokers (DeFi brokers) under these final regulations,” the regulations said.

Read more: IRS finalizes regs for DeFi tax reporting

Paul Atkins of the SEC

David Paul Morris/Bloomberg

SEC chairman nominee Paul Atkins predicted to bring more deregulation

SEC Commissioner Mark Uyeda, who is acting chairman of the agency while Trump nominee Paul Atkins navigates confirmation hearings, expressed the hope that if approved, Atkins will usher in an era of regulatory easing at the agency.

Uyeda said during talks at the AICPA & CIMA Conference on Current SEC and PCAOB Developments in December that he expects an Atkins administration to bring “a return to capital formation” as well as eagerness towards embracing cryptocurrency adoption.

“There are a number of things that we can be doing in this area, not only on the accounting side, but with the disclosures that are required, how you think about this in the context of custody, with respect to auditing crypto reserves,” Uyeda said. “There is so much we can be doing in these areas which I would expect the SEC to try to put renewed focus on.”

Read more: Big changes expected at SEC under new chairman

Crypto tax

It’s the end of universal wallet accounting as we know it

Accountants have been hard at work since October to prepare cryptocurrency clients for the IRS Revenue Procedure 2024-28, which since it went into effect in January has fundamentally uprooted the “universal wallet” reporting standard for crypto holdings — leaving many scrambling to comply.

Rather than allowing taxpayers to report their cryptocurrency balances as a combined amount, they must now report those values to the IRS on a per-account basis.

“You’re talking about going from the universal wallet concept — which is imperfect without a doubt but something we can handle today — to what is, in essence, specific IDs where every wallet needs to be treated as its own universe for tax purposes,” Zach Gordon, founder of cryptocurrency accounting firm Red Five, told AT’s Chris Gaetano.

Read more: CPAs race to prepare clients for end of universal wallet accounting

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Accounting

White House establishes Strategic Bitcoin Reserve

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The White House today issued an executive order formally creating a Strategic Bitcoin Reserve as well as a U.S. Digital Asset Stockpile. 

The reserve will treat bitcoin, the first and most popular blockchain-based cryptocurrency, as a reserve asset. It will be capitalized with tokens owned by the Department of Treasury that was forfeited as part of criminal or civil asset forfeiture proceedings. Other agencies, such as the FBI, will evaluate their legal authority to transfer any bitcoin owned by those agencies to the Strategic Bitcoin Reserve. The administration said that the U.S. will not actually sell these bitcoins, as they would act as a store of reserve assets. The executive order authorizes the Secretaries of Treasury and Commerce to develop budget-neutral strategies for acquiring additional bitcoin, provided that those strategies impose no incremental costs on American taxpayers.

The U.S. Digital Asset Stockpile, meanwhile, will consist of digital assets other than bitcoin owned by the Department of Treasury that was forfeited in criminal or civil asset forfeiture proceedings. Versus the bitcoin reserve, the government will not acquire additional assets for the U.S. Digital Asset Stockpile beyond those obtained through forfeiture proceedings. Also unlike the bitcoin reserve, the Secretary of the Treasury may determine strategies for responsible stewardship, including potential sales from the U.S. Digital Asset Stockpile.

The executive order also says that agencies must provide a full accounting of their digital asset holdings to the Secretary of the Treasury and the President’s Working Group on Digital Asset Markets.

The administration justified the decision by saying that, with a fixed supply of 21 million coins, there is a strategic advantage to being among the first nations to create a Strategic Bitcoin Reserve, though it did not elaborate. It also said that the government currently holds a significant amount of bitcoin but has not maximized its strategic position as a unique store of value in the global financial system. It decried $17 billion worth of what it called “premature” sales of bitcoin. It also pointed out that there has not been a centralized policy for managing digital asset reserves held by the government, so right now holdings are scattered throughout different departments. 

“Taking affirmative steps to centralize ownership, control, and management of these assets within the Federal government will ensure proper oversight, accurate tracking, and a cohesive approach to managing the government’s cryptocurrency holdings. This move harnesses the power of digital assets for national prosperity, rather than letting them languish in limbo,” said the executive order. 

Dr. Sean Stein Smith, a Lehman College accounting professor who is also chair of the Accounting Working Group in the Wall Street Blockchain Alliance, said that while the executive order only sets up a framework for now, there will be significant implications further down the road. One possibility is an increased emphasis on crypto audits, as David Sack, AI and Crypto Czar, stated multiple times that one of the first pieces of business to move the E.O. forward would be to conduct on audit of current U.S. holdings. With buy-in from the Executive branch, and the emphasis on the importance of crypto audits, said Smith, the profession has an opportunity to expand efforts to standardize the currently disparate crypto audit practices.

Another impact will be client FOMO, as people may reason “after all if it is good enough for the U.S. government it should be good enough for me?” It will be especially important for accountants to educate clients about the risk and opportunities of crypto investments as well as to provide advisory services to those clients interested in integrating crypto into operations.

“In short the E.O. establishing an SBR and digital asset stockpile are set to further propel interest in crypto investments and utilization at clients of all sizes. The emphasis on high quality crypto audits, internal control and advisory opportunities as more investors (retail and institutional) potentially move into the sector, and the inevitable tax issues that will arise as a result all present opportunities for the profession,” said Smith in an email.

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Accounting

As AI rises in importance, so too does governance

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AI governance was a major theme of 2024, and as the technology continues to evolve, oversight and control—as well as ways to demonstrate it to others—will become even more important this year. 

This was the assessment of Danny Manimbo, a principal with Top 50 firm Schellman, who is primarily responsible for leading the firm’s AI and ISO practices. Speaking during the firm’s Schellmancon event today, he said that last year saw the release of a number of AI governance frameworks, including the National Institute of Standards and Technology’s AI Risk Management Framework, the International Standards Organization’s ISO 42001, and Microsoft’s revisions to its Supplier Security and Privacy Assurance Program to account for AI. Meanwhile, actual regulation is also gaining momentum, with Manimbo pointing to the EU’s AI Act, South Korea’s AI Basic Act, and a number of state-level regulations such as California’s recent AI laws. 

“That kind of set the tone for a lot of the inquiries and the interest that we saw, and for the trends on where GRC was going in 2024, maybe not so much immediately in the beginning of the year, because the frameworks were so new, but I think they were boosted by a number of things in the regulatory standpoint,” said Manimbo. 

The other panelist, Lisa Hall, chief information security officer for the trust platform SafeBase, added that, given the pace of AI advances, it is likely that last year’s measures were not the end but just the beginning, especially considering how widely used even the current generation of solutions is. 

“I think it’s only going to increase, and everyone seems to have some type of AI offering,” said Hall. “Regulations and standards will likely become more demanding, and even with the shadow IT capabilities we have now, I worry that we may be underestimating how often AI technologies are actually used by our employees. And also, on the flip side, how can we best leverage these to make our lives easier?”

Manimbo noted that, with this rise in control frameworks and regulation, this year will also see a rise in demand for ways to demonstrate that one is aligned and compliant with them. The ISO 42001 certification, for which Schellman recently became the first ANSI-accredited body allowed to audit and grant certification for compliance with the standard, is one example, but he anticipated other avenues will open this year. “For example, I sit on the [Cloud Security Alliance] AI Control Framework [board], and they are launching a program scheduled for the second half of this year which is going to be very similar to their [Security Trust Assurance and Risk] program for cloud security but specific to AI risk. That’ll be another avenue,” he said. He added that other standard setters, like the AICPA, might also decide to update their frameworks to account for AI risk. 

Such demonstrations are vital for establishing customer trust in a world that is increasingly connected. Hall noted that supply chains have grown much more complex, which has allowed attackers new opportunities to target vendors or third party software providers and compromise multiple downstream organizations at once. In such an environment, establishing trust with a customer is vital, but it can often involve lengthy and tedious audits filled with manual processes. While she has had success with some automation, such as using AI to reduce time on customer questionnaires and automate access controls, there remain many things that still need human intervention. 

“I’ve definitely struggled with that, like where an auditor is asking for data sets, you’re coming back with a sample set, you’re bouncing back and forth from a tool to gather evidence, and it becomes even more complex when you’re dealing with customer audits and you’re talking to more than one auditor, and you can only reuse evidence for so long that evidence goes stale,” she said. “And then a lot of times, auditors have competing platforms and tools that may not integrate with yours. So it’s still a manual process. There’s a ton of back and forth communication there. I’m still copying and pasting, I’m still downloading from here and uploading to here. So I’d love to see this process improve,”  

Manimbo noted AI has also been helping processes like this, noting that AI can itself help bolster an organization’s controls through automating routine processes and reducing dependence on manual processes. 

“On this front, some of the things that have plagued us in the past is the amount of context that we need as professionals to know if something is something that needs to be addressed immediately as part of a control failure that may be detected. And I think AI will help provide that context there… It may not necessarily be [about] what the controls may be, but how efficient are the models in augmenting existing automation to find those failures in a way that we can effectively address those findings in a way that we can again improve on those and so hopefully reducing additional burden on a team members,” he said. 

However, with all these different frameworks coming out, and with current ones being revised to account for AI, professionals may be challenged in keeping up with all the changes. Professionals need to not only know how to apply these frameworks but also how to scale them as time goes on. Hall said that, by maintaining a security-focused mindset and being proactive, so that the organization is more able to respond to change. 

“If we build and buy with security in mind and find ways to leverage automation and AI to enable us to quickly adjust, … we’re just going to be way better off,” said Hall.  “Instead of looking at ‘here’s the strict regulation, here’s what I have to do,’ [it is] kind of this afterthought, by being more proactive and just having these things in mind. .. I think it’s about us having that mindset of: How is the security built in? How can I be accountable and prove that I’m doing what I’m doing? And think about that before the auditors show up and before the regulations show up.”

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AICPA in discussions with IRS over tax season jitters

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The American Institute of CPAs is monitoring the situation at the Internal Revenue Service amid reports of layoffs of up to half the staff, keeping in touch with IRS officials about maintaining services during the critical tax season.

“In recent weeks, there has been a flood of information regarding the current state of the IRS, some of which has resulted in conflicting reports, creating confusion,” said AICPA president and CEO Mark Koziel in a statement Friday. “The AICPA is having active discussions with IRS officials to clarify this information and we are actively monitoring developments as the IRS continues to assess the immediate and long-term implications. With the volatility of the present environment and rapidly changing events, it is important to reconcile fact from fiction for taxpayers and their advisors. Despite inconsistent reports, we know that the IRS is making every effort to maintain this tax season’s service levels comparable with that of recent years.”

He stressed the importance of the IRS maintaining service during tax season.

“The ability of the IRS to maintain service levels for taxpayers and their preparers is critically important to the AICPA,” Koziel added. “IRS services in combination with modernization efforts, which include technology advancements, have been the bedrock of AICPA’s recommendations for many years. A modern, functioning IRS is essential for Americans to meet their tax obligations and to our country’s financial health.”

The AICPA is also offering recommendations to the embattled agency. “The AICPA continues to provide recommendations to the IRS that will offer some level of relief as we work diligently to understand the impacts to services offered to taxpayers and their practitioners,” said Koziel. “We offer our voice and support to minimize public confusion about current IRS operations.”

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