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Regulatory or Legal Changes Top 5
Source rules for digital asset validation income
Establishes where mining and staking income is taxed — U.S.-sourced for American earners, foreign-sourced for non-U.S. persons — with special rules for branches, mining pools, and partnerships.
- Population Scope Low Directly affects cryptocurrency miners, stakers, and validation pool participants — both U.S. and foreign — a specialized industry population well under 10% of U.S. adults.
- Budgetary Magnitude Medium Sourcing rules govern the U.S. taxability of validation income, affecting recurring federal tax revenues from mining and staking at scale without any appropriation or funding ceiling.
- Legal / Regulatory Depth High Creates new statutory sourcing rules in the IRC that determine U.S. versus foreign tax jurisdiction over an entire income category, a substantive change with binding legal effect on U.S. and foreign persons.
- Degree of Discretion Granted High Secretary is authorized to issue regulations on branch attribution, mining pool treatment, and partnership-level application, covering foundational questions left unresolved by statute.
- Implementation & Enforcement Burden Medium Requires miners and stakers to track income by source country and entity type, and requires Treasury to develop attribution regulations, adding compliance and rulemaking load.
- Temporal Commitment High Persists indefinitely until Congress acts to repeal it.
No signal yet
Carve-outs, Exemptions, Eligibility Top 5
Tax nonrecognition for stablecoin purchases of goods/services
Eliminates capital gains and losses when people use qualifying dollar-pegged stablecoins to buy goods or services, treating those transactions like cash payments for tax purposes.
- Population Scope Medium Reaches the broad but self-selected population of U.S. taxpayers who use qualifying stablecoins for retail purchases — a growing but still minority share of the public, likely 10–25% of adults given current stablecoin adoption trajectories.
- Budgetary Magnitude Medium Foregoes capital gains revenue on stablecoin purchase transactions at scale, a recurring annual tax expenditure whose magnitude grows with stablecoin adoption but is not appropriated or capped.
- Legal / Regulatory Depth High Creates a new IRC statutory exclusion (§1034) that affirmatively converts stablecoin purchase transactions from taxable property dispositions to nonrecognition events, a substantive change to existing law.
- Degree of Discretion Granted Medium Treasury must publish quarterly qualifying-stablecoin reports and may issue regulations on recordkeeping, basis allocation, and broker reporting, blending mandatory duties with meaningful rulemaking latitude.
- Implementation & Enforcement Burden Medium Imposes an affirmative taxpayer recordkeeping obligation and requires Treasury to maintain a recurring quarterly publication process, adding ongoing compliance and administrative load.
- Temporal Commitment High Same as above.
No signal yet
Regulatory or Legal Changes Top 5
Wash sale rules extended to digital assets
Applies existing wash-sale rules — which prevent investors from claiming a tax loss when they quickly repurchase what they just sold — to digital assets, closing a loophole that currently allows those transactions.
- Population Scope Medium Reaches all individual and institutional digital asset investors — estimated in the tens of millions of U.S. adults — who engage in or could engage in loss-harvesting transactions, approaching a 10–25% population share.
- Budgetary Magnitude Medium Eliminates a recurring loss-harvesting tax strategy, generating additional federal tax revenue each year at a scale tied to investor behavior, with no appropriation or cap.
- Legal / Regulatory Depth High Amends IRC §1091 to impose a statutory loss-disallowance rule on a new asset class, creating a binding substantive prohibition that did not previously apply to digital asset investors.
- Degree of Discretion Granted Low No significant new rulemaking authority is delegated; the provision extends existing wash-sale mechanics to digital assets with limited Secretary discretion beyond standard administration.
- Implementation & Enforcement Burden Medium Requires brokers and investors to track repurchase windows and substantially identical digital asset holdings across accounts, adding recurring compliance obligations and delayed broker reporting until 2028.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility Top 5
De minimis exemption for digital asset network fee payments
Exempts small digital asset transactions — where the value of assets used to pay blockchain network fees is $10 or less — from capital gains taxes, relieving ordinary users from tracking tiny taxable events.
- Population Scope Medium Reaches the broad population of ordinary retail blockchain users who pay small transaction fees — potentially tens of millions of U.S. adults — while excluding professional traders and high-volume users.
- Budgetary Magnitude Low Forgoes capital gains recognition on sub-$10 fee transactions, a per-transaction revenue effect that is individually trivial even if aggregated across many users.
- Legal / Regulatory Depth High Creates new IRC §1044, a new statutory exclusion from gain/loss recognition paired with broker reporting relief, establishing a new enforceable taxpayer entitlement across a defined class of transactions.
- Degree of Discretion Granted Medium Secretary receives explicit authority to issue anti-structuring regulations and implementation guidance, covering both definitional and abuse-prevention gaps left open by the $10 threshold.
- Implementation & Enforcement Burden Medium Requires taxpayers to track per-transaction fee values against the $10 threshold and apply anti-abuse aggregation rules, while reducing broker reporting obligations for qualifying transactions.
- Temporal Commitment High Same as above.
No signal yet
Regulatory or Legal Changes Top 5
Mark-to-market accounting election for digital asset dealers
Lets professional digital asset traders and dealers choose a simplified accounting method that taxes gains and losses annually as ordinary income, similar to rules already in place for stock and commodity dealers.
- Population Scope Low Applies only to professional dealers and traders in covered digital assets, a narrow commercial sector representing a small fraction of the U.S. population.
- Budgetary Magnitude Medium Accelerates ordinary income recognition on unrealized gains for electing dealers, shifting the timing of federal tax revenue rather than appropriating funds, with recurring annual revenue effects.
- Legal / Regulatory Depth High Amends IRC §475 to create a new elective mark-to-market regime and amends IRC §199A to strip digital asset dealers of the pass-through deduction, imposing new substantive statutory obligations and disqualifications.
- Degree of Discretion Granted Medium the IRS and Treasury administer election and revocation procedures and govern the four-year adjustment spread, exercising meaningful procedural discretion within a statutory framework.
- Implementation & Enforcement Burden Medium Requires dealers to track and report unrealized gains and losses annually and manage multi-year accounting method transition adjustments, imposing recurring compliance obligations.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Foreign digital asset trading excluded from U.S. business
Exempts foreign persons who trade digital assets through independent agents or for their own account from being classified as conducting a U.S. business, shielding that trading income from U.S. tax.
- Population Scope Low Applies exclusively to foreign persons trading digital assets through U.S. markets, a narrow non-U.S. population with no direct effect on domestic taxpayers.
- Budgetary Magnitude Medium Permanently forgoes recurring U.S. tax revenue on trading income that would otherwise be attributed to a U.S. trade or business, though the precise revenue effect depends on foreign trader volume.
- Legal / Regulatory Depth High Amends IRC §864(b)(2) to add a new statutory exclusion shielding a category of foreign trading activity from U.S. business classification, a substantive jurisdictional change to existing law.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the provision operates through a self-executing statutory exclusion mirroring existing stock and commodity trading rules.
- Implementation & Enforcement Burden Low Reduces rather than increases enforcement obligations by narrowing the class of foreign traders subject to U.S. business tax, with no new compliance infrastructure required.
- Temporal Commitment High Persists indefinitely until Congress acts to repeal it.
No signal yet
Regulatory or Legal Changes
Tax rules for digital asset investment trusts and partnerships
Sets federal tax classification rules for investment trusts and publicly traded partnerships (PTPs) holding digital assets, allowing staking rewards and digital asset gains to count as qualifying income for PTPs and clarifying trust pass-through status.
- Population Scope Low Directly affects sponsors and investors in digital asset investment trusts and publicly traded partnerships — a narrow institutional and retail investor subset well under 10% of the population.
- Budgetary Magnitude Medium Expands qualifying income for publicly traded partnerships and grants trust pass-through status, affecting recurring federal tax characterization of investment vehicle income without any appropriation.
- Legal / Regulatory Depth High Amends IRC §7701 and §7704 to create new statutory classification rules and expand qualifying income categories for digital asset vehicles, substantively restructuring how these entities are taxed.
- Degree of Discretion Granted Medium Secretary is authorized to prescribe regulations and guidance for digital asset trust classification, covering definitions and operational requirements left open by the statute.
- Implementation & Enforcement Burden Low Primarily resolves classification uncertainty rather than imposing new compliance infrastructure, reducing rather than increasing the administrative burden on investment vehicle operators.
- Temporal Commitment High Same as above.
No signal yet
Regulatory or Legal Changes
Constructive sale rules extended to digital assets
Extends existing constructive sale tax rules to digital assets, meaning investors who hold appreciated digital assets and take offsetting positions must recognize that gain — closing a tax deferral strategy.
- Population Scope Low Affects only sophisticated investors who hold appreciated digital assets and use offsetting or hedging strategies — a narrow subset of the broader digital asset investor population well under 10% of U.S. adults.
- Budgetary Magnitude Medium Closes a gain-deferral strategy, generating additional recurring federal tax revenue whose scale depends on the volume of offsetting positions held by digital asset investors.
- Legal / Regulatory Depth High Amends IRC §1259 to impose a new statutory gain-recognition obligation on holders of appreciated digital asset positions who take offsetting transactions, a substantive change to existing law.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; existing the IRS enforcement of constructive sale rules extends to digital assets under the amended statute.
- Implementation & Enforcement Burden Medium Requires investors to identify and report constructive sale events across tokenized and bridged asset equivalents, adding transactional compliance tracking obligations.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Staking income excluded from UBTI for tax-exempt organizations
Allows nonprofit organizations to earn passive staking rewards on digital assets without those earnings counting as taxable business income, as long as they delegate validation and do not run validator nodes themselves.
- Population Scope Low Applies only to tax-exempt organizations that passively stake digital assets through delegation — charities, foundations, and pension funds — a narrow institutional population well under 10% of U.S. entities.
- Budgetary Magnitude Medium Forgoes recurring UBTI tax revenue on passive staking income earned by a large and growing sector of tax-exempt organizations, without any appropriation or cap.
- Legal / Regulatory Depth High Amends IRC §512(b) to create a new statutory UBTI exclusion for a defined income category, substantively changing the tax obligations of qualifying tax-exempt organizations.
- Degree of Discretion Granted Medium Secretary is directed to issue implementing regulations including anti-abuse provisions defining substantial non-participation, covering key eligibility determinations left open by statute.
- Implementation & Enforcement Burden Medium Requires tax-exempt organizations to document arm's-length delegation, absence of validator node operation, and lack of control over validation, imposing ongoing factual compliance obligations.
- Temporal Commitment High Same as above.
No signal yet
Regulatory or Legal Changes
Non-recognition extended to digital asset lending agreements
Extends existing tax rules that prevent gain or loss recognition on securities loans to cover digital asset loans, and requires borrowers to compensate lenders for staking rewards and protocol distributions earned during the loan period.
- Population Scope Low Directly affects institutional parties to digital asset lending agreements and tax-exempt organizations with lending income — a narrow set of sophisticated market participants well under 10% of the population.
- Budgetary Magnitude Low Does not appropriate or obligate funds; the revenue effect of deferring gain recognition on lending transactions is modest given the relatively small institutional market for digital asset loans.
- Legal / Regulatory Depth High Amends IRC §1058 and §512 to extend nonrecognition treatment and income characterization rules to a new asset class, creating substantive new statutory rights and obligations for lending parties.
- Degree of Discretion Granted Medium Secretary sets the scope of required compensation for staking rewards and protocol distributions under qualifying agreements, a substantive gap-filling authority over a key economic term.
- Implementation & Enforcement Burden Medium Requires lenders and borrowers to structure agreements to meet statutory conditions and track staking reward compensation obligations, adding transactional compliance requirements.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Appraisal exemption for donated widely traded digital assets
Removes the requirement that donors get a formal property appraisal before claiming a charitable deduction for widely traded digital assets, treating them the same as publicly traded stock donations.
- Population Scope Low Applies only to taxpayers who donate widely traded digital assets to qualifying charities — a narrow subset of digital asset holders with philanthropic intent, well under 10% of the population.
- Budgetary Magnitude Low Removes a procedural barrier to charitable deductions rather than authorizing funds; any revenue effect from increased donation claims is modest given the narrow donor population.
- Legal / Regulatory Depth Medium Amends IRC §170(f)(11) to eliminate a procedural compliance requirement for a defined class of donors, a procedural rather than substantive change that aligns digital assets with existing publicly traded security treatment.
- Degree of Discretion Granted Low Treasury retains existing anti-abuse authority to reimpose appraisal requirements but receives no new substantive rulemaking mandate.
- Implementation & Enforcement Burden Low Reduces compliance burden by eliminating the appraisal requirement, with no new enforcement infrastructure or reporting obligations created.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exemption from information reporting
Section 6045 of such Code is amended by adding at the end the following new subsection: In the case of the sale, exchange, or disposition of any covered payment stablecoin for which no gain or loss is recognized under section 1034(a), no return shall be required under subsection (a). The Secretary…
- Population Scope Low Affects only brokers processing qualifying stablecoin transactions — a narrow class of financial intermediaries — with no direct effect on most taxpayers.
- Budgetary Magnitude Low Does not authorize or appropriate funds; eliminates a reporting requirement rather than affecting tax revenue directly.
- Legal / Regulatory Depth Medium Amends IRC §6045 to eliminate a broker reporting obligation for a defined transaction class, a procedural change to an existing compliance duty rather than a new substantive legal obligation.
- Degree of Discretion Granted Medium Secretary retains authority to prescribe conditions under which brokers may rely on customer certifications for the exemption, preserving meaningful administrative discretion.
- Implementation & Enforcement Burden Low Reduces broker compliance burden by eliminating return-filing obligations for qualifying stablecoin transactions, with no new enforcement mechanisms created.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exception for certain acquisitions of digital assets
Section 1091 of such Code, as amended by subsection (b), is further amended by adding at the end the following new subsection: This section shall not apply with respect to the acquisition of a digital asset if such digital asset is acquired— in connection with the validation of digital asset…
- Population Scope Low Applies only to miners and stakers who acquire digital assets through validation activity, a narrow specialist population well under 10% of U.S. adults.
- Budgetary Magnitude Low Does not authorize or appropriate funds; carves out a class of acquisitions from wash-sale rules without creating a new tax expenditure of meaningful scale.
- Legal / Regulatory Depth Medium Adds a targeted statutory exception to IRC §1091 for a defined acquisition type, a procedural carve-out that limits the reach of a new substantive rule rather than itself creating a new substantive obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the exception is self-executing based on how the digital asset was acquired.
- Implementation & Enforcement Burden Low Reduces compliance obligations for miners and stakers by excluding their acquisitions from wash-sale tracking, with no new reporting or enforcement requirements.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exception for certain acquisitions of digital assets
This section shall not apply with respect to the acquisition of a digital asset if such digital asset is acquired— in connection with the validation of digital asset transactions (including digital asset validation supporting activities), or in a transaction which is part of a regular or periodic…
- Population Scope Low Applies only to taxpayers who acquire digital assets through validation activity or as ordinary income in a regular series — a narrow specialist population well under 10% of U.S. adults.
- Budgetary Magnitude Low Does not authorize or appropriate funds; limits the scope of wash-sale application without creating a new tax expenditure of independent magnitude.
- Legal / Regulatory Depth Medium Adds a targeted statutory carve-out to IRC §1091 for a defined acquisition pattern, limiting the reach of the broader wash-sale extension rather than creating a new substantive legal obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the exception operates automatically based on the statutory acquisition criteria.
- Implementation & Enforcement Burden Low Reduces compliance burden for qualifying taxpayers by excluding their acquisitions from wash-sale tracking, with no new enforcement mechanisms.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exception for certain mark-to-Market positions
Section 1091 of such Code, as amended by subsections (b) and (c), is further amended by adding at the end the following new subsection: This section shall not apply with respect to any specified asset to which subsection (a) of section 475 applies (including by reason of an election under…
- Population Scope Low Applies only to digital asset dealers and traders who have elected or are subject to mark-to-market accounting under IRC §475, a narrow commercial population well under 10% of U.S. adults.
- Budgetary Magnitude Low Does not authorize or appropriate funds; prevents double application of loss-recognition regimes without independently affecting federal revenue at meaningful scale.
- Legal / Regulatory Depth Medium Adds a coordination rule to IRC §1091 preventing overlap between wash-sale and mark-to-market regimes, a procedural boundary between two statutory schemes rather than a new substantive obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the exception is self-executing based on whether §475 mark-to-market applies.
- Implementation & Enforcement Burden Low Reduces compliance complexity for mark-to-market filers by clarifying they are not also subject to wash-sale rules, with no new reporting or enforcement requirements.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exception for certain mark-to-Market positions
This section shall not apply with respect to any specified asset to which subsection (a) of section 475 applies (including by reason of an election under subsection (e), (f), or (g) of such section).
- Population Scope Low Applies only to dealers and traders subject to or electing mark-to-market accounting under IRC §475, a narrow commercial population well under 10% of U.S. adults.
- Budgetary Magnitude Low Does not authorize or appropriate funds; eliminates potential double-counting of losses without independently creating a new tax expenditure.
- Legal / Regulatory Depth Medium Functions as a coordination rule preventing dual application of wash-sale and mark-to-market loss regimes, a procedural clarification rather than a new substantive statutory obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the provision is self-executing based on the taxpayer's mark-to-market status.
- Implementation & Enforcement Burden Low Reduces rather than adds compliance burden by clarifying the scope of wash-sale inapplicability for mark-to-market filers.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exception for wash sales
Except as otherwise provided by the Secretary, the customer’s adjusted basis shall be determined without regard to section 1091 (relating to loss from wash sales of specified assets) unless the transactions occur in the same account with respect to identical specified assets. For purposes of…
- Population Scope Low Applies to brokers and their customers in the context of basis determination for wash-sale purposes — a narrow transactional context affecting a subset of digital asset investors.
- Budgetary Magnitude Low Does not authorize or appropriate funds; governs a basis-calculation methodology without independently affecting federal revenue at meaningful scale.
- Legal / Regulatory Depth Medium Creates a basis-determination rule limiting cross-account wash-sale adjustments, a procedural clarification to an existing statutory scheme rather than a new substantive obligation.
- Degree of Discretion Granted Medium Secretary retains authority to prescribe alternative basis-determination rules, preserving meaningful administrative flexibility over cross-account wash-sale treatment.
- Implementation & Enforcement Burden Low Simplifies broker basis-reporting obligations by limiting wash-sale adjustments to same-account identical asset transactions, reducing rather than increasing compliance burden.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Nonapplication to validating trade or business
This subsection shall not apply in the case of any entity or arrangement engaged in the active conduct of a trade or business of validating digital asset transactions.
- Population Scope Low Applies only to entities actively engaged in a trade or business of digital asset validation — a narrow commercial population well under 10% of U.S. entities.
- Budgetary Magnitude Low Does not authorize or appropriate funds; excludes active validators from a benefit rather than creating a new tax expenditure.
- Legal / Regulatory Depth Medium Limits the scope of a newly created UBTI exclusion by carving out active validators, a procedural boundary on a substantive rule rather than itself creating a new obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the carve-out is self-executing based on whether the entity actively conducts a validation trade or business.
- Implementation & Enforcement Burden Low Requires active validators to confirm they do not qualify for the UBTI exclusion, a minor factual determination with no new reporting infrastructure.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exception from appraisal requirements
Section 170(f)(11)(A)(ii)(I) of the Internal Revenue Code of 1986 is amended by inserting widely traded digital assets (except as the Secretary determines appropriate to prevent abuse of this section), after publicly traded securities (as defined in section 6050L(a)(2)(B)), .
- Population Scope Low Applies only to taxpayers donating widely traded digital assets to charity — a narrow subset of digital asset holders with philanthropic intent, well under 10% of the population.
- Budgetary Magnitude Low Removes a procedural barrier to charitable deductions without authorizing funds; any incremental revenue effect from additional donation claims is modest.
- Legal / Regulatory Depth Medium Amends IRC §170(f)(11) to eliminate a procedural compliance requirement for a defined donor class, aligning digital assets with existing publicly traded security treatment without creating a new substantive obligation.
- Degree of Discretion Granted Low Secretary retains existing anti-abuse authority to reimpose appraisal requirements but receives no new substantive rulemaking mandate.
- Implementation & Enforcement Burden Low Reduces compliance burden by eliminating the appraisal requirement for qualifying donors, with no new enforcement infrastructure created.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exemption from information reporting
Section 6045(i) of such Code, as added by section 2 of this Act, is amended— by redesignating paragraph (2) as paragraph (3), and by inserting after paragraph (1) the following new paragraph: Except as otherwise provided by the Secretary or under subparagraph (B), in the case of the disposition of…
- Population Scope Low Affects only brokers processing qualifying de minimis fee dispositions — a narrow class of financial intermediaries — with no direct effect on most taxpayers.
- Budgetary Magnitude Low Does not authorize or appropriate funds; eliminates a reporting obligation for sub-$10 transactions whose individual tax value is trivial.
- Legal / Regulatory Depth Medium Amends IRC §6045(i) to eliminate broker reporting obligations for a defined class of small transactions, a procedural change to an existing compliance duty rather than a new substantive legal obligation.
- Degree of Discretion Granted Medium Secretary retains authority to prescribe conditions or override the exemption, preserving meaningful administrative discretion over when reporting is required.
- Implementation & Enforcement Burden Low Reduces broker compliance burden by eliminating return-filing obligations for qualifying de minimis fee dispositions, with no new enforcement mechanisms created.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exception for qualified transaction cost dispositions
This section shall not apply with respect to any qualified transaction cost disposition (as defined in section 1044(b)).
- Population Scope Low Applies only to the specific class of de minimis fee dispositions qualifying under IRC §1044(b) — a narrow transactional subset affecting retail blockchain users making sub-$10 fee payments.
- Budgetary Magnitude Low Does not authorize or appropriate funds; the reporting exemption has no independent revenue effect beyond what IRC §1044 itself foregoes.
- Legal / Regulatory Depth Medium Creates a cross-reference carve-out in IRC §6045(i) tying broker reporting relief to §1044 eligibility, a coordination rule between two statutory provisions rather than a new substantive obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated beyond what §1044 itself grants; the exemption is self-executing based on §1044(b) eligibility.
- Implementation & Enforcement Burden Low Reduces compliance burden for brokers by eliminating reporting obligations for qualifying fee dispositions, with no new enforcement requirements.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Exception for certain acquisitions
For purposes of the application of section 1091 of the Internal Revenue Code of 1986 with respect to any digital asset acquired before the date of enactment of this Act, the amendments made by this section shall be deemed to not apply.
No signal yet
Regulatory or Legal Changes
Stablecoin and digital asset obligation registration rules
Exempts qualifying stablecoins from rules that restrict unregistered debt obligations, and sets rules for how digital asset issuers satisfy disclosure requirements, including a deemed 25-year maturity date for assets with no fixed term.
No signal yet
Regulatory or Legal Changes
Treasury guidance on DAO foreign entity tax reorganizations
Requires the Treasury Department to issue rules within one year explaining how foreign entities connected to decentralized autonomous organizations (DAOs) can reorganize as U.S. corporations for tax purposes, with safe harbors for early movers.
No signal yet
Carve-outs, Exemptions, Eligibility
Exception for certain acquisitions
For purposes of the application of section 1091 of the Internal Revenue Code of 1986 with respect to any digital asset acquired before the date of enactment of this Act, the amendments made by this section shall be deemed to not apply.
No signal yet
Regulatory or Legal Changes
Stablecoin and digital asset obligation registration rules
Exempts qualifying stablecoins from rules that restrict unregistered debt obligations, and sets rules for how digital asset issuers satisfy disclosure requirements, including a deemed 25-year maturity date for assets with no fixed term.
No signal yet
Regulatory or Legal Changes
Treasury guidance on DAO foreign entity tax reorganizations
Requires the Treasury Department to issue rules within one year explaining how foreign entities connected to decentralized autonomous organizations (DAOs) can reorganize as U.S. corporations for tax purposes, with safe harbors for early movers.
No signal yet
Summary
The Aligning Digital Assets with Principles of Taxation Act (ADAPT Act) updates U.S. tax law to address how digital assets like cryptocurrency are bought, sold, and held. Right now, most digital asset transactions trigger capital gains taxes, even small everyday purchases. Among other elements, the bill * exempts stable-value digital currencies (stablecoins) used to buy everyday goods and services from capital gains taxes; * extends wash-sale rules — which prevent investors from claiming fake losses — to digital assets; * allows professional digital asset traders to use a simplified accounting method called mark-to-market; * sets rules for where mining and staking income is taxed, depending on whether the earner is a U.S. or foreign person; * creates a small exemption for transaction fees under $10 on blockchain networks; and exempts tax-exempt organizations from business-income taxes on passive staking rewards.
AI-generated summary, pending human review.
| Version | Event | Date | User support | Your vote | Roll calls |
|---|---|---|---|---|---|
| Original |
Initial publication
Sep 30, 2026
|
Sep 30, 2026 | No votes yet | — | — |
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Regulatory or Legal Changes Top 5
Source rules for digital asset validation income
Establishes where mining and staking income is taxed — U.S.-sourced for American earners, foreign-sourced for non-U.S. persons — with special rules for branches, mining pools, and partnerships.
- Population Scope Low Directly affects cryptocurrency miners, stakers, and validation pool participants — both U.S. and foreign — a specialized industry population well under 10% of U.S. adults.
- Budgetary Magnitude Medium Sourcing rules govern the U.S. taxability of validation income, affecting recurring federal tax revenues from mining and staking at scale without any appropriation or funding ceiling.
- Legal / Regulatory Depth High Creates new statutory sourcing rules in the IRC that determine U.S. versus foreign tax jurisdiction over an entire income category, a substantive change with binding legal effect on U.S. and foreign persons.
- Degree of Discretion Granted High Secretary is authorized to issue regulations on branch attribution, mining pool treatment, and partnership-level application, covering foundational questions left unresolved by statute.
- Implementation & Enforcement Burden Medium Requires miners and stakers to track income by source country and entity type, and requires Treasury to develop attribution regulations, adding compliance and rulemaking load.
- Temporal Commitment High Persists indefinitely until Congress acts to repeal it.
No signal yet
Regulatory or Legal Changes
Source rules for digital asset validation income
Carve-outs, Exemptions, Eligibility Top 5
Tax nonrecognition for stablecoin purchases of goods/services
Eliminates capital gains and losses when people use qualifying dollar-pegged stablecoins to buy goods or services, treating those transactions like cash payments for tax purposes.
- Population Scope Medium Reaches the broad but self-selected population of U.S. taxpayers who use qualifying stablecoins for retail purchases — a growing but still minority share of the public, likely 10–25% of adults given current stablecoin adoption trajectories.
- Budgetary Magnitude Medium Foregoes capital gains revenue on stablecoin purchase transactions at scale, a recurring annual tax expenditure whose magnitude grows with stablecoin adoption but is not appropriated or capped.
- Legal / Regulatory Depth High Creates a new IRC statutory exclusion (§1034) that affirmatively converts stablecoin purchase transactions from taxable property dispositions to nonrecognition events, a substantive change to existing law.
- Degree of Discretion Granted Medium Treasury must publish quarterly qualifying-stablecoin reports and may issue regulations on recordkeeping, basis allocation, and broker reporting, blending mandatory duties with meaningful rulemaking latitude.
- Implementation & Enforcement Burden Medium Imposes an affirmative taxpayer recordkeeping obligation and requires Treasury to maintain a recurring quarterly publication process, adding ongoing compliance and administrative load.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
Tax nonrecognition for stablecoin purchases of goods/services
Regulatory or Legal Changes Top 5
Wash sale rules extended to digital assets
Applies existing wash-sale rules — which prevent investors from claiming a tax loss when they quickly repurchase what they just sold — to digital assets, closing a loophole that currently allows those transactions.
- Population Scope Medium Reaches all individual and institutional digital asset investors — estimated in the tens of millions of U.S. adults — who engage in or could engage in loss-harvesting transactions, approaching a 10–25% population share.
- Budgetary Magnitude Medium Eliminates a recurring loss-harvesting tax strategy, generating additional federal tax revenue each year at a scale tied to investor behavior, with no appropriation or cap.
- Legal / Regulatory Depth High Amends IRC §1091 to impose a statutory loss-disallowance rule on a new asset class, creating a binding substantive prohibition that did not previously apply to digital asset investors.
- Degree of Discretion Granted Low No significant new rulemaking authority is delegated; the provision extends existing wash-sale mechanics to digital assets with limited Secretary discretion beyond standard administration.
- Implementation & Enforcement Burden Medium Requires brokers and investors to track repurchase windows and substantially identical digital asset holdings across accounts, adding recurring compliance obligations and delayed broker reporting until 2028.
- Temporal Commitment High Same as above.
No signal yet
Regulatory or Legal Changes
Wash sale rules extended to digital assets
Carve-outs, Exemptions, Eligibility Top 5
De minimis exemption for digital asset network fee payments
Exempts small digital asset transactions — where the value of assets used to pay blockchain network fees is $10 or less — from capital gains taxes, relieving ordinary users from tracking tiny taxable events.
- Population Scope Medium Reaches the broad population of ordinary retail blockchain users who pay small transaction fees — potentially tens of millions of U.S. adults — while excluding professional traders and high-volume users.
- Budgetary Magnitude Low Forgoes capital gains recognition on sub-$10 fee transactions, a per-transaction revenue effect that is individually trivial even if aggregated across many users.
- Legal / Regulatory Depth High Creates new IRC §1044, a new statutory exclusion from gain/loss recognition paired with broker reporting relief, establishing a new enforceable taxpayer entitlement across a defined class of transactions.
- Degree of Discretion Granted Medium Secretary receives explicit authority to issue anti-structuring regulations and implementation guidance, covering both definitional and abuse-prevention gaps left open by the $10 threshold.
- Implementation & Enforcement Burden Medium Requires taxpayers to track per-transaction fee values against the $10 threshold and apply anti-abuse aggregation rules, while reducing broker reporting obligations for qualifying transactions.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility
De minimis exemption for digital asset network fee payments
Regulatory or Legal Changes Top 5
Mark-to-market accounting election for digital asset dealers
Lets professional digital asset traders and dealers choose a simplified accounting method that taxes gains and losses annually as ordinary income, similar to rules already in place for stock and commodity dealers.
- Population Scope Low Applies only to professional dealers and traders in covered digital assets, a narrow commercial sector representing a small fraction of the U.S. population.
- Budgetary Magnitude Medium Accelerates ordinary income recognition on unrealized gains for electing dealers, shifting the timing of federal tax revenue rather than appropriating funds, with recurring annual revenue effects.
- Legal / Regulatory Depth High Amends IRC §475 to create a new elective mark-to-market regime and amends IRC §199A to strip digital asset dealers of the pass-through deduction, imposing new substantive statutory obligations and disqualifications.
- Degree of Discretion Granted Medium the IRS and Treasury administer election and revocation procedures and govern the four-year adjustment spread, exercising meaningful procedural discretion within a statutory framework.
- Implementation & Enforcement Burden Medium Requires dealers to track and report unrealized gains and losses annually and manage multi-year accounting method transition adjustments, imposing recurring compliance obligations.
- Temporal Commitment High Same as above.
No signal yet
Regulatory or Legal Changes
Mark-to-market accounting election for digital asset dealers
Carve-outs, Exemptions, Eligibility
Foreign digital asset trading excluded from U.S. business
Exempts foreign persons who trade digital assets through independent agents or for their own account from being classified as conducting a U.S. business, shielding that trading income from U.S. tax.
- Population Scope Low Applies exclusively to foreign persons trading digital assets through U.S. markets, a narrow non-U.S. population with no direct effect on domestic taxpayers.
- Budgetary Magnitude Medium Permanently forgoes recurring U.S. tax revenue on trading income that would otherwise be attributed to a U.S. trade or business, though the precise revenue effect depends on foreign trader volume.
- Legal / Regulatory Depth High Amends IRC §864(b)(2) to add a new statutory exclusion shielding a category of foreign trading activity from U.S. business classification, a substantive jurisdictional change to existing law.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the provision operates through a self-executing statutory exclusion mirroring existing stock and commodity trading rules.
- Implementation & Enforcement Burden Low Reduces rather than increases enforcement obligations by narrowing the class of foreign traders subject to U.S. business tax, with no new compliance infrastructure required.
- Temporal Commitment High Persists indefinitely until Congress acts to repeal it.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Foreign digital asset trading excluded from U.S. business
Regulatory or Legal Changes
Tax rules for digital asset investment trusts and partnerships
Sets federal tax classification rules for investment trusts and publicly traded partnerships (PTPs) holding digital assets, allowing staking rewards and digital asset gains to count as qualifying income for PTPs and clarifying trust pass-through status.
- Population Scope Low Directly affects sponsors and investors in digital asset investment trusts and publicly traded partnerships — a narrow institutional and retail investor subset well under 10% of the population.
- Budgetary Magnitude Medium Expands qualifying income for publicly traded partnerships and grants trust pass-through status, affecting recurring federal tax characterization of investment vehicle income without any appropriation.
- Legal / Regulatory Depth High Amends IRC §7701 and §7704 to create new statutory classification rules and expand qualifying income categories for digital asset vehicles, substantively restructuring how these entities are taxed.
- Degree of Discretion Granted Medium Secretary is authorized to prescribe regulations and guidance for digital asset trust classification, covering definitions and operational requirements left open by the statute.
- Implementation & Enforcement Burden Low Primarily resolves classification uncertainty rather than imposing new compliance infrastructure, reducing rather than increasing the administrative burden on investment vehicle operators.
- Temporal Commitment High Same as above.
No signal yet
Regulatory or Legal Changes (optional)
Tax rules for digital asset investment trusts and partnerships
Regulatory or Legal Changes
Constructive sale rules extended to digital assets
Extends existing constructive sale tax rules to digital assets, meaning investors who hold appreciated digital assets and take offsetting positions must recognize that gain — closing a tax deferral strategy.
- Population Scope Low Affects only sophisticated investors who hold appreciated digital assets and use offsetting or hedging strategies — a narrow subset of the broader digital asset investor population well under 10% of U.S. adults.
- Budgetary Magnitude Medium Closes a gain-deferral strategy, generating additional recurring federal tax revenue whose scale depends on the volume of offsetting positions held by digital asset investors.
- Legal / Regulatory Depth High Amends IRC §1259 to impose a new statutory gain-recognition obligation on holders of appreciated digital asset positions who take offsetting transactions, a substantive change to existing law.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; existing the IRS enforcement of constructive sale rules extends to digital assets under the amended statute.
- Implementation & Enforcement Burden Medium Requires investors to identify and report constructive sale events across tokenized and bridged asset equivalents, adding transactional compliance tracking obligations.
- Temporal Commitment High Same as above.
No signal yet
Regulatory or Legal Changes (optional)
Constructive sale rules extended to digital assets
Carve-outs, Exemptions, Eligibility
Staking income excluded from UBTI for tax-exempt organizations
Allows nonprofit organizations to earn passive staking rewards on digital assets without those earnings counting as taxable business income, as long as they delegate validation and do not run validator nodes themselves.
- Population Scope Low Applies only to tax-exempt organizations that passively stake digital assets through delegation — charities, foundations, and pension funds — a narrow institutional population well under 10% of U.S. entities.
- Budgetary Magnitude Medium Forgoes recurring UBTI tax revenue on passive staking income earned by a large and growing sector of tax-exempt organizations, without any appropriation or cap.
- Legal / Regulatory Depth High Amends IRC §512(b) to create a new statutory UBTI exclusion for a defined income category, substantively changing the tax obligations of qualifying tax-exempt organizations.
- Degree of Discretion Granted Medium Secretary is directed to issue implementing regulations including anti-abuse provisions defining substantial non-participation, covering key eligibility determinations left open by statute.
- Implementation & Enforcement Burden Medium Requires tax-exempt organizations to document arm's-length delegation, absence of validator node operation, and lack of control over validation, imposing ongoing factual compliance obligations.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Staking income excluded from UBTI for tax-exempt organizations
Regulatory or Legal Changes
Non-recognition extended to digital asset lending agreements
Extends existing tax rules that prevent gain or loss recognition on securities loans to cover digital asset loans, and requires borrowers to compensate lenders for staking rewards and protocol distributions earned during the loan period.
- Population Scope Low Directly affects institutional parties to digital asset lending agreements and tax-exempt organizations with lending income — a narrow set of sophisticated market participants well under 10% of the population.
- Budgetary Magnitude Low Does not appropriate or obligate funds; the revenue effect of deferring gain recognition on lending transactions is modest given the relatively small institutional market for digital asset loans.
- Legal / Regulatory Depth High Amends IRC §1058 and §512 to extend nonrecognition treatment and income characterization rules to a new asset class, creating substantive new statutory rights and obligations for lending parties.
- Degree of Discretion Granted Medium Secretary sets the scope of required compensation for staking rewards and protocol distributions under qualifying agreements, a substantive gap-filling authority over a key economic term.
- Implementation & Enforcement Burden Medium Requires lenders and borrowers to structure agreements to meet statutory conditions and track staking reward compensation obligations, adding transactional compliance requirements.
- Temporal Commitment High Same as above.
No signal yet
Regulatory or Legal Changes (optional)
Non-recognition extended to digital asset lending agreements
Carve-outs, Exemptions, Eligibility
Appraisal exemption for donated widely traded digital assets
Removes the requirement that donors get a formal property appraisal before claiming a charitable deduction for widely traded digital assets, treating them the same as publicly traded stock donations.
- Population Scope Low Applies only to taxpayers who donate widely traded digital assets to qualifying charities — a narrow subset of digital asset holders with philanthropic intent, well under 10% of the population.
- Budgetary Magnitude Low Removes a procedural barrier to charitable deductions rather than authorizing funds; any revenue effect from increased donation claims is modest given the narrow donor population.
- Legal / Regulatory Depth Medium Amends IRC §170(f)(11) to eliminate a procedural compliance requirement for a defined class of donors, a procedural rather than substantive change that aligns digital assets with existing publicly traded security treatment.
- Degree of Discretion Granted Low Treasury retains existing anti-abuse authority to reimpose appraisal requirements but receives no new substantive rulemaking mandate.
- Implementation & Enforcement Burden Low Reduces compliance burden by eliminating the appraisal requirement, with no new enforcement infrastructure or reporting obligations created.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Appraisal exemption for donated widely traded digital assets
Carve-outs, Exemptions, Eligibility
Exemption from information reporting
Section 6045 of such Code is amended by adding at the end the following new subsection: In the case of the sale, exchange, or disposition of any covered payment stablecoin for which no gain or loss is recognized under section 1034(a), no return shall be required under subsection (a). The Secretary…
- Population Scope Low Affects only brokers processing qualifying stablecoin transactions — a narrow class of financial intermediaries — with no direct effect on most taxpayers.
- Budgetary Magnitude Low Does not authorize or appropriate funds; eliminates a reporting requirement rather than affecting tax revenue directly.
- Legal / Regulatory Depth Medium Amends IRC §6045 to eliminate a broker reporting obligation for a defined transaction class, a procedural change to an existing compliance duty rather than a new substantive legal obligation.
- Degree of Discretion Granted Medium Secretary retains authority to prescribe conditions under which brokers may rely on customer certifications for the exemption, preserving meaningful administrative discretion.
- Implementation & Enforcement Burden Low Reduces broker compliance burden by eliminating return-filing obligations for qualifying stablecoin transactions, with no new enforcement mechanisms created.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Exemption from information reporting
Carve-outs, Exemptions, Eligibility
Exception for certain acquisitions of digital assets
Section 1091 of such Code, as amended by subsection (b), is further amended by adding at the end the following new subsection: This section shall not apply with respect to the acquisition of a digital asset if such digital asset is acquired— in connection with the validation of digital asset…
- Population Scope Low Applies only to miners and stakers who acquire digital assets through validation activity, a narrow specialist population well under 10% of U.S. adults.
- Budgetary Magnitude Low Does not authorize or appropriate funds; carves out a class of acquisitions from wash-sale rules without creating a new tax expenditure of meaningful scale.
- Legal / Regulatory Depth Medium Adds a targeted statutory exception to IRC §1091 for a defined acquisition type, a procedural carve-out that limits the reach of a new substantive rule rather than itself creating a new substantive obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the exception is self-executing based on how the digital asset was acquired.
- Implementation & Enforcement Burden Low Reduces compliance obligations for miners and stakers by excluding their acquisitions from wash-sale tracking, with no new reporting or enforcement requirements.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Exception for certain acquisitions of digital assets
Carve-outs, Exemptions, Eligibility
Exception for certain acquisitions of digital assets
This section shall not apply with respect to the acquisition of a digital asset if such digital asset is acquired— in connection with the validation of digital asset transactions (including digital asset validation supporting activities), or in a transaction which is part of a regular or periodic…
- Population Scope Low Applies only to taxpayers who acquire digital assets through validation activity or as ordinary income in a regular series — a narrow specialist population well under 10% of U.S. adults.
- Budgetary Magnitude Low Does not authorize or appropriate funds; limits the scope of wash-sale application without creating a new tax expenditure of independent magnitude.
- Legal / Regulatory Depth Medium Adds a targeted statutory carve-out to IRC §1091 for a defined acquisition pattern, limiting the reach of the broader wash-sale extension rather than creating a new substantive legal obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the exception operates automatically based on the statutory acquisition criteria.
- Implementation & Enforcement Burden Low Reduces compliance burden for qualifying taxpayers by excluding their acquisitions from wash-sale tracking, with no new enforcement mechanisms.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Exception for certain acquisitions of digital assets
Carve-outs, Exemptions, Eligibility
Exception for certain mark-to-Market positions
Section 1091 of such Code, as amended by subsections (b) and (c), is further amended by adding at the end the following new subsection: This section shall not apply with respect to any specified asset to which subsection (a) of section 475 applies (including by reason of an election under…
- Population Scope Low Applies only to digital asset dealers and traders who have elected or are subject to mark-to-market accounting under IRC §475, a narrow commercial population well under 10% of U.S. adults.
- Budgetary Magnitude Low Does not authorize or appropriate funds; prevents double application of loss-recognition regimes without independently affecting federal revenue at meaningful scale.
- Legal / Regulatory Depth Medium Adds a coordination rule to IRC §1091 preventing overlap between wash-sale and mark-to-market regimes, a procedural boundary between two statutory schemes rather than a new substantive obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the exception is self-executing based on whether §475 mark-to-market applies.
- Implementation & Enforcement Burden Low Reduces compliance complexity for mark-to-market filers by clarifying they are not also subject to wash-sale rules, with no new reporting or enforcement requirements.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Exception for certain mark-to-Market positions
Carve-outs, Exemptions, Eligibility
Exception for certain mark-to-Market positions
This section shall not apply with respect to any specified asset to which subsection (a) of section 475 applies (including by reason of an election under subsection (e), (f), or (g) of such section).
- Population Scope Low Applies only to dealers and traders subject to or electing mark-to-market accounting under IRC §475, a narrow commercial population well under 10% of U.S. adults.
- Budgetary Magnitude Low Does not authorize or appropriate funds; eliminates potential double-counting of losses without independently creating a new tax expenditure.
- Legal / Regulatory Depth Medium Functions as a coordination rule preventing dual application of wash-sale and mark-to-market loss regimes, a procedural clarification rather than a new substantive statutory obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the provision is self-executing based on the taxpayer's mark-to-market status.
- Implementation & Enforcement Burden Low Reduces rather than adds compliance burden by clarifying the scope of wash-sale inapplicability for mark-to-market filers.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Exception for certain mark-to-Market positions
Carve-outs, Exemptions, Eligibility
Exception for wash sales
Except as otherwise provided by the Secretary, the customer’s adjusted basis shall be determined without regard to section 1091 (relating to loss from wash sales of specified assets) unless the transactions occur in the same account with respect to identical specified assets. For purposes of…
- Population Scope Low Applies to brokers and their customers in the context of basis determination for wash-sale purposes — a narrow transactional context affecting a subset of digital asset investors.
- Budgetary Magnitude Low Does not authorize or appropriate funds; governs a basis-calculation methodology without independently affecting federal revenue at meaningful scale.
- Legal / Regulatory Depth Medium Creates a basis-determination rule limiting cross-account wash-sale adjustments, a procedural clarification to an existing statutory scheme rather than a new substantive obligation.
- Degree of Discretion Granted Medium Secretary retains authority to prescribe alternative basis-determination rules, preserving meaningful administrative flexibility over cross-account wash-sale treatment.
- Implementation & Enforcement Burden Low Simplifies broker basis-reporting obligations by limiting wash-sale adjustments to same-account identical asset transactions, reducing rather than increasing compliance burden.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Exception for wash sales
Carve-outs, Exemptions, Eligibility
Nonapplication to validating trade or business
This subsection shall not apply in the case of any entity or arrangement engaged in the active conduct of a trade or business of validating digital asset transactions.
- Population Scope Low Applies only to entities actively engaged in a trade or business of digital asset validation — a narrow commercial population well under 10% of U.S. entities.
- Budgetary Magnitude Low Does not authorize or appropriate funds; excludes active validators from a benefit rather than creating a new tax expenditure.
- Legal / Regulatory Depth Medium Limits the scope of a newly created UBTI exclusion by carving out active validators, a procedural boundary on a substantive rule rather than itself creating a new obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated; the carve-out is self-executing based on whether the entity actively conducts a validation trade or business.
- Implementation & Enforcement Burden Low Requires active validators to confirm they do not qualify for the UBTI exclusion, a minor factual determination with no new reporting infrastructure.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Nonapplication to validating trade or business
Carve-outs, Exemptions, Eligibility
Exception from appraisal requirements
Section 170(f)(11)(A)(ii)(I) of the Internal Revenue Code of 1986 is amended by inserting widely traded digital assets (except as the Secretary determines appropriate to prevent abuse of this section), after publicly traded securities (as defined in section 6050L(a)(2)(B)), .
- Population Scope Low Applies only to taxpayers donating widely traded digital assets to charity — a narrow subset of digital asset holders with philanthropic intent, well under 10% of the population.
- Budgetary Magnitude Low Removes a procedural barrier to charitable deductions without authorizing funds; any incremental revenue effect from additional donation claims is modest.
- Legal / Regulatory Depth Medium Amends IRC §170(f)(11) to eliminate a procedural compliance requirement for a defined donor class, aligning digital assets with existing publicly traded security treatment without creating a new substantive obligation.
- Degree of Discretion Granted Low Secretary retains existing anti-abuse authority to reimpose appraisal requirements but receives no new substantive rulemaking mandate.
- Implementation & Enforcement Burden Low Reduces compliance burden by eliminating the appraisal requirement for qualifying donors, with no new enforcement infrastructure created.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Exception from appraisal requirements
Carve-outs, Exemptions, Eligibility
Exemption from information reporting
Section 6045(i) of such Code, as added by section 2 of this Act, is amended— by redesignating paragraph (2) as paragraph (3), and by inserting after paragraph (1) the following new paragraph: Except as otherwise provided by the Secretary or under subparagraph (B), in the case of the disposition of…
- Population Scope Low Affects only brokers processing qualifying de minimis fee dispositions — a narrow class of financial intermediaries — with no direct effect on most taxpayers.
- Budgetary Magnitude Low Does not authorize or appropriate funds; eliminates a reporting obligation for sub-$10 transactions whose individual tax value is trivial.
- Legal / Regulatory Depth Medium Amends IRC §6045(i) to eliminate broker reporting obligations for a defined class of small transactions, a procedural change to an existing compliance duty rather than a new substantive legal obligation.
- Degree of Discretion Granted Medium Secretary retains authority to prescribe conditions or override the exemption, preserving meaningful administrative discretion over when reporting is required.
- Implementation & Enforcement Burden Low Reduces broker compliance burden by eliminating return-filing obligations for qualifying de minimis fee dispositions, with no new enforcement mechanisms created.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Exemption from information reporting
Carve-outs, Exemptions, Eligibility
Exception for qualified transaction cost dispositions
This section shall not apply with respect to any qualified transaction cost disposition (as defined in section 1044(b)).
- Population Scope Low Applies only to the specific class of de minimis fee dispositions qualifying under IRC §1044(b) — a narrow transactional subset affecting retail blockchain users making sub-$10 fee payments.
- Budgetary Magnitude Low Does not authorize or appropriate funds; the reporting exemption has no independent revenue effect beyond what IRC §1044 itself foregoes.
- Legal / Regulatory Depth Medium Creates a cross-reference carve-out in IRC §6045(i) tying broker reporting relief to §1044 eligibility, a coordination rule between two statutory provisions rather than a new substantive obligation.
- Degree of Discretion Granted Low No new rulemaking authority is delegated beyond what §1044 itself grants; the exemption is self-executing based on §1044(b) eligibility.
- Implementation & Enforcement Burden Low Reduces compliance burden for brokers by eliminating reporting obligations for qualifying fee dispositions, with no new enforcement requirements.
- Temporal Commitment High Same as above.
No signal yet
Carve-outs, Exemptions, Eligibility (optional)
Exception for qualified transaction cost dispositions
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