9/21/2026 - By Michael Cole, JD, MSPA & Stacey Craig, CPA
If you use Venmo, PayPal, online marketplaces, or crypto, it’s easy to assume the tax rules work like this: “No tax form, no taxes.” That’s a common (and expensive) misconception.
Two big ideas to keep straight: (1) reporting rules tell companies when to send forms to the IRS, and (2) tax rules decide whether something is taxable. Crypto adds a third twist: the tax result depends on what you did (buy, sell, get paid, stake, mine, etc.).
Form 1099-K comes from a law (IRC Section 6050W) that requires certain payment networks to report payment activity to the IRS. For many third-party payment networks (think some apps and online marketplaces), reporting generally kicks in only if you exceed both of these during the year:
That’s the federal reporting threshold many people have heard about.
But here’s what that threshold doesn’t mean:
The IRS’s view is simple: income can be taxable even if you never receive a Form 1099-K.
Also, Form 1099-K shows gross payments not your profit. It usually doesn’t subtract things like:
So even when you do get a 1099-K, the number on it is just the starting point.
The $20,000/200 rule is mainly talked about for certain third-party payment networks. But card payments (credit/debit) are treated differently those transactions can be reportable even without that same threshold.
This matters if you sell across multiple channels: you might get a 1099-K from one platform and nothing from another, while the underlying income is still reportable either way.
People use the phrase “digital payments” to describe everything from paying a friend to running a business online. Examples include payments through apps (like PayPal and similar platforms), online marketplace payouts, getting paid in cryptocurrency, stablecoin transfers, or trades through crypto exchanges.
Important: the 1099-K threshold is not a special “crypto tax rule.” It’s a payment reporting rule. Whether your activity is taxable depends on what the payment was actually for.
For instance:
Bottom line: a tax form (or lack of one) doesn’t decide the tax outcome.
Crypto Is Usually Taxed Like Property
For U.S. federal income taxes, most digital assets are treated as property (not like foreign currency). So the usual “property” tax rules apply.
That means:
This surprises people: if you spend crypto that went up in value, you may owe tax on the gain—similar to if you sold it for cash first and then spent the cash.
Crypto isn’t taxed one single way. The result depends on the activity.
1) Holding Crypto as an Investment
If you hold crypto as an investment, it’s often treated like a capital asset. When you sell or trade it, you typically have a capital gain or loss.
It’s similar to stocks but recordkeeping (especially basis) can be trickier with crypto.
2) Mining and Staking Rewards
Mining and staking rewards are generally ordinary income when you receive them, based on the asset’s fair market value at that time.
That value becomes your basis. If you later sell the coins/tokens, you may have another tax event (capital gain or loss) based on the change in value since you received them.
3) Airdrops and Hard Forks
Airdrops and hard forks can also create ordinary income often when you have “dominion and control,” meaning you can actually access, transfer, or sell the new asset.
So you could owe tax even before you convert anything to dollars.
4) Stablecoins
Stablecoins are generally still treated as property for federal tax purposes. The fact that they aim to stay near a fixed price doesn’t automatically make them tax-free.
In real life, gains/losses may be smaller than with volatile coins but the same framework typically applies unless the law changes.
5) NFTs and Other One-Of-One Assets
NFTs generally fit into the same “digital assets are property” idea, but they can be harder in practice because of:
Because NFTs can be unique and thinly traded, backing up your valuation can be much harder than with widely traded tokens.
Usually, where you trade doesn’t change the basic federal tax treatment, crypto is still generally treated as property whether you use a U.S. exchange, a foreign exchange, or a decentralized platform.
But location can matter a lot for reporting, records, and compliance risk.
U.S. Exchanges
U.S. custodial exchanges are more likely to generate tax forms and clean transaction histories. That can make filing easier, but it also means more visibility.
Foreign Exchanges
Using a foreign exchange doesn’t remove your duty to report income. It can, however, mean:
Decentralized Platforms (DeFi)
DeFi often has the biggest DIY burden: fewer tax forms, messier data, and more work to rebuild your transaction history. The lack of a form still doesn’t change the tax rules.
So the exchange may not change whether gain is taxable but it can change how easy it is to track basis, document transactions, and meet reporting obligations.
When you’re dealing with digital payments or crypto, separate these three questions:
Mixing these up is where people get into trouble, for example, assuming “no 1099” means “no income,” or reporting the full 1099-K amount as profit without backing out basis and expenses.
And remember: exchange location usually doesn’t change the underlying federal tax treatment—but it can affect reporting, documentation, and compliance headaches.
The most practical lesson: don’t use a reporting threshold—or the absence of a tax form—as your test for whether something is taxable. Start with what actually happened in the transaction, then make sure your records support the numbers you report.
Digital payments and cryptocurrency transactions can create complex tax reporting requirements—even if you never receive a tax form. Whether you're selling online, accepting payments through third-party apps, or investing in digital assets, understanding your reporting obligations can help you avoid costly mistakes and IRS scrutiny.
The experienced tax professionals at Saltmarsh can help you navigate evolving tax rules, maintain accurate records, and develop strategies tailored to your financial situation.
About the Authors
Michael is a partner with experience across tax, accounting, and advisory services. He began his career in public accounting over 15 years ago, focusing on tax consulting and compliance. His primary areas of experience include providing services related to mergers and acquisitions, 704(b) allocations, and complex transaction structuring for private equity firms and family offices.
Stacey is a partner with experience across tax compliance, planning, and consulting services. Stacey is a trusted tax advisor known for delivering clear, strategic guidance that helps clients make confident financial decisions. With more than two decades of experience in tax compliance, planning, and consulting, she brings deep expertise to partnerships, S corporations, nonprofits, high-net-worth individuals, trusts, and estates.