When assets move between platforms, cost basis data can disappear. The receiving often cannot rebuild the original purchase record. As a result, the system does not match the way crypto ownership works across networks.
The report says the burden then shifts to the taxpayer. Users must reconstruct their full transaction history. If they get it wrong, they face audit exposure and possible compliance problems.
The issue also affects smaller firms. The Clarity Act includes a de minimis exemption for low-volume brokers and dealers. That relief may protect the smallest startups, but it leaves mid-sized firms with steep technical costs.
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Other jurisdictions are also shaping their rules. The OECD’s Crypto-Asset Reporting Framework, or CARF, takes a standardized data approach across platforms. It does not assume that intermediaries can rebuild perfect cost basis histories for every user.
The broader policy gap remains. Federal rules now support innovation and a clearer market structure. Yet tax reporting still expects a level of precision that fragmented crypto activity cannot always deliver.
