Oct. 15, 2023
Dear Internal Revenue Service (IRS) and Treasury Department, I am writing to provide feedback on the proposed regulations discussed in the document titled "Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions." I have reviewed the summary provided, and I would like to express my concerns regarding poorly defined terms within the proposed regulations. As stated in the summary, the document proposes regulations concerning the information reporting and determination of amount realized and basis for certain digital asset sales and exchanges. However, it is essential to note that the proposed regulations utilize poorly defined terms that are susceptible to multiple interpretations. For example, the use of the term "platform" is not clearly defined, resulting in potential confusion for brokers and other stakeholders involved in digital asset transactions. Additionally, the document also provides definitions for terms such as "wallet," "smart contracts," and "validator" that do not reflect their technical meaning accurately. This discrepancy further contributes to a lack of clarity and understanding in the proposed regulations. To ensure effective implementation and compliance, it is crucial to establish clear and precise definitions for key industry terms in relation to digital asset transactions. By doing so, you can mitigate confusion among brokers, digital asset trading platforms, and other stakeholders who are expected to comply with these regulations. I appreciate the opportunity to provide feedback on these proposed regulations, and I trust that my concerns regarding the poorly defined terms can be addressed. Clarifying these definitions will undoubtedly contribute to a more seamless and well-founded set of regulations for the digital asset industry. Thank you for your attention to this matter, and I look forward to the resolution of these concerns. Sincerely, Jeremy Blunt