Oct. 14, 2023
Dear Internal Revenue Service and Treasury Department, I hope this letter finds you well. Firstly, I would like to commend the effort put into the proposed regulations regarding information reporting and the determination of amount realized and basis for certain digital asset sales and exchanges. It is a step towards bringing more clarity and structure to the evolving world of digital assets. I have carefully reviewed the PDF document titled "Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions" and would like to provide my feedback on the key points summarized into the 10 sections. One aspect that caught my attention is the issue of poorly defined terms. I understand the complexity of defining terms in the context of digital assets, as the technology itself is rapidly evolving. However, it is crucial to have precise and well-defined terms in order to avoid confusion and ensure compliance. For instance, the use of terms like "platform" without proper definition may invite multiple interpretations. Additionally, terms like "wallet," "smart contracts," and "validator" should incorporate their technical meanings to accurately capture their functions in relation to digital assets. Without these clear definitions, there is a risk of misinterpretation and potential compliance challenges. I would strongly recommend working towards refining these terms and providing comprehensive definitions that align with the technical aspects of digital assets. This will ensure that the regulations are implemented effectively and consistently, allowing for better compliance and understanding within the digital asset community. Thank you for considering my feedback on this matter. I appreciate the efforts put forth by the Internal Revenue Service and Treasury Department in proposing these regulations. With further refinement, I believe that they will contribute positively to the digital asset landscape. If you require any additional information or would like to discuss this matter further, please do not hesitate to reach out to me. I look forward to seeing the progression of these regulations and the positive impact they will have on the digital asset industry. Yours sincerely, Joe