A new US crypto tax reporting rule has taken effect, adding fresh compliance pressure for individuals and businesses that receive large digital asset payments in the course of trade or business. Under a provision tied to the Infrastructure Investment and Jobs Act passed in 2021, anyone in the United States who receives $10,000 or more in cryptocurrency as part of business activity must file a report with the Internal Revenue Service within 15 days of the transaction.
The rule became effective on January 1, 2024, but it has continued to draw attention because of the serious legal consequences attached to noncompliance and the lack of practical guidance surrounding how the requirement is supposed to work in many on-chain situations. Coin Center, a crypto policy research and advocacy organization, has warned that failure to submit the report on time could expose a recipient to felony liability.
Who the rule applies to
One of the most important clarifications highlighted by Coin Center is that the obligation does not apply only to registered companies or formal business entities. It can also apply to individuals if they receive the crypto in the course of their trade or business. That means a person operating as an individual miner, validator, day trader, or NFT creator may still fall within the scope of the law even without an incorporated company structure.
According to Coin Center Executive Director Jerry Brito, the rule covers more than traditional merchant-style payment activity. If an individual receives a qualifying amount of crypto while conducting income-generating activity that could be considered a trade or business, the reporting duty may still be triggered. Brito specifically noted that this interpretation could reach miners, traders, and NFT artists, among others.
At the same time, he also pointed out a major unresolved issue: there is no bright-line rule clearly defining what counts as a “trade or business” in every crypto-related case. That uncertainty matters because it affects who is expected to comply and when.
What must be reported
As described by Coin Center, the required filing is expected to include identifying details about the sender or payer, such as the person’s name, address, and Social Security number, along with the amount received, the date of the transaction, and the nature of the payment. On paper, this resembles longstanding reporting standards used for large cash transactions.
In practice, however, cryptocurrency transactions often do not resemble conventional cash payments. Many blockchain-based transfers occur without direct access to the counterparty’s legal identity, tax information, or physical address. This creates immediate compliance tension between the legal requirement and the technological structure of decentralized networks.
Major questions remain unanswered
Coin Center has argued that the biggest challenge is not simply the burden of filing, but the fact that the government has not yet clearly explained how recipients are expected to comply in many common crypto scenarios.
For example, Brito raised the issue of block rewards. If a miner or validator receives rewards worth more than $10,000, whose identifying information are they supposed to report? In a decentralized network, there may be no obvious counterparty that maps neatly onto the reporting form required under traditional cash rules.
He also questioned how the law should apply in an on-chain decentralized exchange transaction. If one party receives $10,000 or more in cryptocurrency during a crypto-to-crypto swap, it is not always clear who should be treated as the payer for reporting purposes. The problem becomes even more complicated when trying to determine how to value the crypto at the moment of receipt, especially in volatile markets where prices may vary depending on the data source and timing methodology used.
Another unresolved scenario involves anonymous donations. If someone sends bitcoin or ether to a public wallet address without revealing their identity, the recipient may have no way to collect the legal information the law appears to require. Yet the filing obligation may still exist if the amount exceeds the threshold and the recipient obtained it in the course of trade or business.
No clear IRS guidance and no dedicated crypto form
Brito also emphasized that the IRS has not issued comprehensive guidance answering these operational questions. That lack of clarity is especially significant because the reporting system appears to rely on structures originally designed for cash transactions, not decentralized digital asset transfers.
Under existing rules, large cash receipts are commonly reported using Form 8300. But while cryptocurrency is treated as “cash” for purposes of this legal framework, Treasury has not fully explained how crypto transactions should be reported on that form. The mismatch has added to industry concern that the rule is in force before the government has established a workable compliance pathway.
There is also a procedural complication involving the Financial Crimes Enforcement Network, or FinCEN. Form 8300 is currently sent not only to the IRS but also to FinCEN. Coin Center argues that, unlike with physical cash transactions, FinCEN does not have authority to collect reports concerning cryptocurrency transactions in the same way. If that interpretation is correct, then simply applying the existing form and process to crypto may raise additional legal and administrative issues.
Legal challenge is ongoing
Coin Center filed a lawsuit against the US Treasury Department in June 2022, challenging the constitutionality of the reporting requirement. The organization has argued that the law creates serious privacy and due process concerns while imposing obligations that may be impossible to satisfy in decentralized contexts.
However, the case is still moving through the courts, and there has been no final ruling that would suspend the law’s effect. As a result, Coin Center’s position is that affected parties still have an obligation to comply for now, even though the organization believes the current framework is deeply flawed and in some cases unworkable.
This creates a difficult environment for the crypto sector. Businesses and individuals may face meaningful legal risk for failing to report, yet they may not have enough official guidance to know what complete compliance actually looks like. That tension is particularly acute in sectors such as mining, validation, NFT creation, decentralized trading, and blockchain-native services where counterparty identity is often unavailable by design.
Why the rule matters for the industry
The significance of this rule goes beyond one filing obligation. It reflects the broader direction of US digital asset policy, where lawmakers and regulators are increasingly trying to extend legacy financial reporting frameworks into crypto markets. The aim is to strengthen tax enforcement and reduce blind spots around large-value transfers. But the crypto industry has repeatedly argued that rules designed for banked, identifiable, and intermediary-driven systems do not always map cleanly onto decentralized networks.
For market participants, the immediate takeaway is that this is not a hypothetical proposal anymore. The reporting requirement is already in force, the threshold is $10,000, and the filing window is 15 days. At the same time, critical implementation questions remain unresolved, including who counts as the payer, how valuation should be determined, what constitutes a trade or business, and which reporting channels are legally appropriate.
Until the IRS or Treasury provides clearer instructions—or the courts intervene—US-based crypto participants engaged in business activity may need to assess their exposure carefully. For some, that may mean seeking legal and tax advice on how to document transaction value, preserve wallet records, and evaluate whether a receipt falls within the law’s scope. For others, especially those operating in decentralized environments, the challenge may be that the information required by the rule is simply not available.
In short, the new law marks a notable escalation in US crypto tax oversight. But while the compliance obligation is now active, the operational roadmap remains incomplete. That gap between legal mandate and practical execution is likely to remain a central issue for the industry as regulatory scrutiny intensifies.