IRS

The IRS is the federal tax authority any US-facing fintech affiliate program needs to surface — it sets the forms, the reporting thresholds, and the enforcement posture that determine how affiliate-recommended products integrate with US filers’ tax workflows. For crypto-tax-software specifically, the IRS released Form 1099-DA (digital asset proceeds from broker transactions) for Tax Year 2025 filings due April 15 2026 — the first-ever IRS form purpose-built for digital assets, and the dominant policy story shaping the entire crypto-tax-affiliate category in 2026. Centralized exchanges (Coinbase, Kraken, Gemini, Crypto.com, etc.) were required to issue 1099-DAs for the first time; the critical caveat is that cost basis is only required for COVERED ASSETS acquired on or after January 1 2026, meaning most TY2025 1099-DAs arrived with PROCEEDS reported but COST BASIS missing — forcing manual reconciliation and a forecast Q3-Q4 2026 wave of CP2000 mismatch notices when filer-reported gains diverge from IRS-computed proceeds.

For affiliate creators themselves, the IRS exposure is via Form 1099-NEC reporting of affiliate income above the $600 annual threshold (issued by the affiliate program or network), Form 8949 + Schedule D for any capital-gains-tax events on crypto holdings, and Schedule 1 for other income (staking rewards, airdrops, interest income under Rev. Rul. 2023-14). Affiliates running a US LLC or sole-proprietorship structure file Schedule C alongside; corporate-entity affiliates file Form 1120 or 1120-S. FTC affiliate-disclosure rules (16 CFR § 255) operate adjacent to but separately from IRS reporting — both apply simultaneously. For prop-trading, robo-advisor, stock/ETF broker, and crypto-exchange/wallet niches, the IRS plays a parallel role on the customer side (1099-B for broker transactions, 1099-MISC for trader earnings, 1099-K for payment-processor flows) — affiliate content should surface the relevant form numbers when recommending products that generate them.