Digital Nomad
Digital Asset Reporting: What Brokers and Nomads Should Know Now
New IRS rules for digital asset reporting under section 6045 and related relief notices affect brokers, digital nomads, and freelancers—learn what’s required, what’s exempted, and how to avoid penalties.
By NomadicTax Research Team • 5-8 min read • November 18, 2025
## Overview of the Digital Asset Reporting Requirements
The IRS has issued **final regulations** under IRC § 6045 requiring brokers to report:
- **Gross proceeds** for digital asset transactions starting **Jan 1, 2025**; basis reporting for certain transactions starting **Jan 1, 2026**. ([irs.gov](https://www.irs.gov/filing/digital-assets?utm_source=openai))
- **Fair market value of digital assets** paid by buyers and received by sellers in real estate transactions with closing dates on or after **Jan 1, 2026**. ([irs.gov](https://www.irs.gov/filing/digital-assets?utm_source=openai))
Some transactions, like wrapping/unwrapping, staking, lending, and short sales of digital assets, are temporarily excepted under Notice 2024-57 until IRS provides further guidance. ([irs.gov](https://www.irs.gov/filing/digital-assets?utm_source=openai))
## Transitional Relief & Safe Harbors
To avoid penalizing brokers and digital nomads during this implementation:
- **Notice 2024-56** and **Notice 2025-33** provide relief from penalty for failure to file Form 1099-DA and furnish payee statements in 2025, as long as there’s a **good faith effort** to report correctly. ([irs.gov](https://www.irs.gov/filing/digital-assets?utm_source=openai))
- Relief also applies to **backup withholding obligations** and associated penalties, especially during transitions into the full reporting regime. In 2027, relief continues for brokers with preexisting customers who satisfy TIN matching or have non-U.S. addresses. ([irs.gov](https://www.irs.gov/filing/digital-assets?utm_source=openai))
## Specific Notes for Digital Nomads & Freelancers Abroad
- If you use platforms or brokers to transact in digital assets, basis reporting is only mandatory from 2026 for certain categories—gross proceeds must be reported beginning 2025. Pay attention to whether your transactions fall under reportable activity.
- Certain brokers, including those handling stablecoins and NFTs, may allow aggregated reporting or apply **de minimis thresholds**. Check with your service providers. ([irs.gov](https://www.irs.gov/filing/digital-assets?utm_source=openai))
- Nomads with transactions that are lending, staking or other exceptions under Notice 2024-57 are currently not required to report those via Forms 1099-DA, but that exception may change. Stay tuned.
## Practical Steps to Stay Compliant
- Maintain **records of cost basis**, time stamps, fair market values for all digital asset transactions from 2025 onward. Useful even in years when basis reporting isn’t required by all brokers.
- Verify whether your broker offers TIN matching services and includes adequate address documentation, especially if you reside abroad.
- Collaborate with your tax advisor to structure your transactions in light of reporting thresholds and safe harbors.
## Example Scenario
**Freelancer-Nomad in Southeast Asia**
- Uses a U.S. broker to trade NFTs and stablecoins. In 2025, the broker reports gross proceeds via 1099-DA. Basis reporting starts only in 2026 for certain categories.
- Creates and retains consolidated records to satisfy future basis reporting and backup withholding relief, especially if he obtains TIN matching or has non-U.S. residence documentation.
**Bottom line:** You won’t be penalized in 2025 if you make a sincere effort, but you must be prepared.