The IRS has begun using a new information request in certain cryptocurrency examinations that expands the scope of digital asset disclosures requested from individual taxpayers.
As part of an Information Document Request (IDR), taxpayers may be asked to complete a form titled “List of Digital Asset Platforms, Wallets, Services, and Products Used (Individual Taxpayers).” This request asks taxpayers to identify the digital asset platforms, wallets, and services they have used over time, including activity outside the specific year under examination.
Scope of Information Requested
The form includes a list of more than one hundred digital asset platforms, encompassing both U.S. and non‑U.S. exchanges. Taxpayers are asked to indicate whether they have used each platform, when use began, and the associated username or email address. Because many platforms have changed names, merged, or discontinued operations, careful review is important to ensure accurate identification.
In addition to centralized exchanges, the request extends to self‑custody wallets and decentralized finance activity, including:
- Software and hardware wallets
- Blockchain networks used
- The general nature of digital asset activity
This reflects the IRS’s broader approach to understanding digital asset activity beyond traditional exchanges.
Certification and Recordkeeping
The completed form must be signed under penalties of perjury by the taxpayer (and spouse, if filing jointly), certifying that the information provided is true, correct, and complete to the best of their knowledge.
Taxpayers are encouraged to gather and retain available records, such as transaction histories, account statements, wallet addresses, and prior tax filings. Where records are incomplete, reasonable efforts to reconstruct historical activity may be helpful in demonstrating good‑faith compliance.
Examination Considerations
Information provided on the form may be reviewed alongside other data sources, including exchange reporting and blockchain analytics. In some cases, disclosures may lead to follow‑up questions or additional document requests.
Bottom Line
This information request represents a more comprehensive approach to digital asset inquiries in IRS examinations. Taxpayers who receive this request should review it carefully and consider consulting with a tax advisor before responding. Taxpayers who have engaged in digital asset activity but are not currently under examination may wish to organize records proactively.
Disclosures:
This information is intended to be educational and is not tailored to the investment needs of any specific investor or client. The information herein is general in nature and should not be considered legal, financial, or tax advice. Consult an attorney or tax professional regarding your specific situation. Views expressed are as of the date indicated, based on the information available at that time, and may change without notice based on market or other conditions. TAG Associates LLC does not assume any duty to update any of the information.
Investing in digital assets involves significant risk, including risk of principal. Any reference to financial instruments such as digital assets should not be construed as an offer, solicitation, recommendation, endorsement, or advice given by TAG Associates LLC, its affiliated entities, officers, or employees, of investing in such products. Please consult with a qualified professional before making any financial decisions.