For years, crypto lived in a reporting gap: taxable in the US like any property, but with no broker paperwork flowing to the IRS the way stock sales generate it. That gap is now closing on a schedule. Starting with transactions from the beginning of 2025, US digital asset brokers — including many custodial exchanges where retail users trade — must report customers’ sale proceeds and other reportable dispositions to the IRS on a new dedicated form, with the first wave of those forms reaching taxpayers during the 2026 filing season. Reporting of cost basis phases in a year behind, for assets acquired from 2026 onward.

The design will be familiar to anyone who has read this site’s account-reporting coverage: the government building an institutional data feed to match against what individuals self-report (FATCA vs FBAR: Your Bank Reports You, and You Still Have to Report Yourself describes the same architecture for bank accounts). Crypto is being wired into the matching machine.

The expat-specific twist

For Americans abroad, the new regime has a sharp asymmetry worth understanding precisely.

The reporting duty falls, for now, on US digital asset brokers. An expat trading on a foreign platform — the local exchange in their country of residence, which is often the practical choice abroad — will generally receive no form at all. DeFi, self-custody, and some foreign-broker activity may also sit outside the current Form 1099-DA reporting flow, but that affects broker reporting, not the taxpayer’s duty to calculate and report gains. And here is where a dangerous inference beckons: no form arriving has never meant no duty. The IRS’s own guidance on the new form says it plainly — transactions through foreign brokers must still be reported on the return, form or no form. An American abroad’s worldwide income has always included crypto gains, wherever the platform sits (I Moved Abroad — Do I Still Have to File US Taxes? ); the new regime changes who else is telling the IRS, not whether you must.

The asymmetry creates a familiar risk profile: the expat whose US broker now reports them and whose foreign exchange reports nothing has one visible account and one invisible one — and this site has covered at length why relying on invisibility is the worst strategy available (The Quiet Disclosure: Why Just Filing the Old Forms Is the Riskiest Middle Path ). The direction of travel is also one-way: international crypto information-exchange frameworks are developing, so foreign-platform silence should be treated as temporary rather than permanent.

The practical problem to solve this year

The first-wave forms will often report proceeds without basis, because brokers are not required to report basis for 2025 sales — the form says what you sold for, not what you paid. Anyone whose records can’t establish acquisition cost risks a gain calculation that resolves badly against them, the same substantiation failure this site describes for property (How Long to Keep Foreign Account Records — and Why the Usual Answer Is Wrong for You) — sharpened here by exchanges that shut down, wallets migrated, and platforms with no export button. For an expat there’s a second layer: transactions denominated in local currency need converting on the same discipline as everything else (One Income, Two Currencies: Which Exchange Rate You’re Supposed to Use ).

The one-hour version of readiness: export full transaction histories from every platform ever used — especially the foreign and defunct ones — while access still exists, and reconcile whatever forms arrive against your own records rather than treating the broker’s number as gospel. The event here isn’t a new tax. It’s the end of the era when nobody was checking the math.

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