If the proposed effective dates are retained in the final regulations, businesses will not have much time to do this. Most of the information required to be reported (e.g., customer data, name and number of units of digital assets sold, gross proceeds, transaction ID and wallet address) would need to be collected beginning in 2025, but presumably, no one will want to program their systems until the regulations are finalized. As of writing, more than 120,000comments had been filed in response to the proposed regulations. These will take some time for the government to review and consider, so it seems unlikely that Treasury and the IRS could issue final regulations before Spring or even Summer 2024. This seems like an enormous lift for companies that do not currently collect any customer data, as they do not have any of the required systems in place.

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Author: Lisa Zarlenga, Shree Sharma

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