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Understanding the New Compliance Landscape
The 2025 regulatory changes fundamentally altered the crypto compliance landscape. Where previously crypto businesses could operate with informal structures and basic record-keeping, the new environment demands institutional-quality systems and documentation. Your initial assessment must identify not just current compliance status, but the client's readiness for ongoing regulatory obligations that will only increase over time.
The wallet-by-wallet requirement under IRC Section 1012(c) alone creates enormous complexity for any business with multiple exchange accounts or wallet addresses. Form 1099-DA implementation means the IRS now has unprecedented visibility into crypto transactions, while CARF creates international information sharing that eliminates the possibility of geographic arbitrage for compliance avoidance.
Your onboarding process must comprehensively map the client's current situation while identifying immediate risks that require urgent attention. This isn't just about documenting what exists—it's about preparing a foundation for ongoing compliance that can adapt to future regulatory developments.
Initial Client Intake Framework
Entity Structure Documentation Checklist
Crypto businesses often operate through complex entity structures that require careful mapping to understand compliance obligations and optimization opportunities. Document ALL entities involved:
- Parent corporation details (state, EIN, formation date)
- Subsidiary entities and ownership percentages
- Foreign entities and jurisdictions
Many crypto businesses use multiple entities for operational, tax, or regulatory reasons. Understanding the complete structure is essential because the new regulations apply different requirements at each entity level, and optimization opportunities often involve restructuring relationships between entities.
Crypto Holdings Inventory Template
The foundation of all crypto tax compliance is a comprehensive understanding of what digital assets the client holds and how they're classified. For each digital asset holding, document:
