Subject: S7–04–23
From: Tony Munoz
Affiliation:

Oct. 17, 2023

Dear Internal Revenue Service (IRS) and Treasury Department,


I have 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 some comments on the proposed regulations. Specifically, I have concerns regarding the following topics:


1. Privacy: I am worried about the privacy and safety implications of allowing multiple third parties to have access to my sensitive financial data and social security number. It is crucial to ensure that adequate measures are in place to protect the privacy of individuals participating in digital asset transactions.


2. Impact Abroad: The proposed regulations do not appear to sufficiently limit reporting requirements for protocols operated outside the United States, as well as for users located outside the U.S. It is essential to consider the international impact and compliance challenges associated with these regulations.


3. Poorly Defined Terms: The proposed regulations utilize undefined terms such as "platform," "software," and "ledger," which can have multiple interpretations. Additionally, the definitions provided for terms like "wallet" and "validator" do not accurately describe their technical meaning. This lack of clarity and consistency may lead to confusion and misinterpretation of the regulations.


I urge the IRS and Treasury Department to address these concerns in the proposed regulations to ensure the protection of privacy, consider the international impact, and provide clear and precise definitions for key terms.


Thank you for the opportunity to provide feedback on this important matter.