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Keegan is an associate in the firm’s Tax practice. He focuses his practice on tax structuring, tax modeling, and other tax advisory services for transactions.

On March 5, 2026, the IRS issued proposed regulations (the Proposed Regulations) setting forth an alternative process for digital asset brokers to obtain consent from customers to receive Form 1099-DA statements electronically. This alternative process provided in the Proposed Regulations is meant to alleviate administrative tax compliance burdens for digital asset brokers. The IRS and Treasury also issued Notice 2026-4, requesting public comments on whether (i) less burdensome consent procedures should be implemented for other payee statements, including Form 1099-B, and (ii) the list of forms permitted on a Form 1099-B composite statement should include Form 1099-MISC for the purpose of reporting “staking rewards,” (i.e., additional units of cryptocurrency granted in exchange for holders locking up assets held in native cryptocurrency to help validate and secure the blockchain).

In 2025, the U.S. digital asset landscape evolved more dramatically than in any year since the industry’s inception. A pro‑innovation White House, an active Congress, and key regulators — including the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Office of the Comptroller of the Currency (OCC), the Department of

On November 10, 2025, the IRS issued Rev. Proc. 2025-31 (the Rev Proc.), which provides a safe harbor for investment trusts and grantor trusts to stake certain digital assets without jeopardizing their status as trusts for U.S. federal income tax purposes. The Rev. Proc. comes in response to the White House’s request made in July 2025 for published guidance on this topic.[1]

The Report authored by the Presidential Working Group on Digital Assets Markets (PWG), titled “Strengthening American Leadership in Digital Financial Technology,” along with the accompanying fact sheet, outlines several key objectives aimed at positioning the U.S. as a leader in digital asset markets. Among its objectives are reinforcing the role of the U.S. dollar, modernizing Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) rules for the digital assets ecosystem, and ensuring fairness and predictability by establishing clear regulatory oversight.

We are pleased to share with you our latest publication, “Navigating Change: First 100 Days under the Trump Administration,” authored by our Digital Assets + Blockchain team. This retrospective examines the pivotal developments in the digital assets industry during the initial phase of the Trump administration.