Stablecoins are no longer a fringe experiment. They have moved quietly and decisively into the financial mainstream, showing up in cross-border payments, corporate treasury operations, and vendor settlement workflows across sectors. The pace of adoption has been fast, but the pace of compliance infrastructure to match it has not.
The GENIUS Act changed that conversation, by establishing a long-awaited regulatory framework, formalizing reserve requirements, and setting standards for stablecoin issuers. And the IRS did not wait for the regulatory debate to settle, either: Form 1099‑DA reporting took effect for the 2025 tax year, requiring brokers and digital asset platforms to report transaction proceeds to the IRS, with an additional cost basis reporting requirement beginning with transactions occurring in 2026.
Yet this is not a planning year. The preparation window is already open, and it will not stay open long. The businesses that will come through it cleanly are the ones building their documentation infrastructure right now, not the ones waiting for more guidance.
The market already knows this, with mainstream financial institutions already building for a stablecoin-integrated world. Wells Fargo recently filed a trademark for “WFUSD,” covering crypto trading, payments, and tokenization services. Nasdaq partnered with Kraken to push toward 24/7 tokenized stock trading. The businesses that haven’t started their compliance planning, meanwhile, are already behind the curve.
Under current IRS guidance, stablecoins are still treated as property rather than currency. That distinction carries enormous weight. Every time a business uses a stablecoin to pay a vendor, settle a transaction, or rebalance a treasury position, it is potentially triggering a taxable event, a gain or loss calculated on the difference between the cost basis at acquisition and the fair market value at the time of use. For companies running high volumes of stablecoin transactions, this creates a tracking burden that most accounting systems were never built to handle. Cost basis must be maintained across multiple wallets, exchanges, and payment platforms, often in real time. Without a dedicated cost basis engine or a well-documented tracking methodology, businesses are flying blind into audit season.
There is some potential relief being discussed. De minimis thresholds that would exempt small-dollar transactions from gain/loss recognition have come up in legislative circles, but they are not yet law. Businesses should not build their compliance strategy around solutions that have not yet been enacted.
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Getting ahead of this does not require a massive technology overhaul. It requires a structured approach to three core areas, and those areas work best when they are treated as one, connected system:
1. The first area is transaction documentation, which means recording every stablecoin transaction with the acquisition date, cost basis, fair market value at the time of use, and the purpose of the transaction, building a single source of truth that satisfies both IRS requirements and GENIUS Act-driven disclosure and certification standards where applicable.
2. The second area is cost basis methodology, which means selecting and consistently applying an accounting method across every wallet and platform. Inconsistent methodology is one of the most common findings in digital asset audits and one of the easiest to prevent.
3. The final area is internal controls, which means connecting the data that tax teams need with the speed that finance and treasury functions depend on.
The broader regulatory debate, including the ongoing discussion around the CLARITY Act and its implications for CFTC and SEC oversight, reflects a landscape that is still evolving. But the tax obligations are already a current priority. If your stablecoin transaction documentation was not airtight for the 2025 tax year, the time to remediate is today. The cost of preparation is a fraction of the cost of remediation.
Stablecoins are becoming a standard part of the financial toolkit. The compliance infrastructure to support them needs to be standard, too.
ABOUT THE AUTHOR:
Kelley A. Chartier, CPA, is a principal in the Tax Group at top 100 accounting firm Wolf & Company, where she serves as the firm’s tax lead for the financial institution and digital assets industries. Kelley has more than 17 years of experience planning tax engagements, preparing and reviewing income tax provisions, and performing tax review services for corporations. Her expertise includes state income and franchise tax nexus and compliance, as well as comprehensive tax projection and planning services. Kelley works closely with clients to develop strategic tax planning initiatives that optimize their tax positions and support their business objectives.
Photo credit: Gri-spb/iStock
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Tags: compliance, digital assets, Form 1099-DA, GENIUS Act, IRS, stablecoins, Tax Planning, Taxes
