,i  #aaith ,,congress  #b;d ,session    
,h4 ,r4 #iagh  ,,in ,,the ,,house ,,of  
,,representatives  ,june #h1 #bjbf,mr4  
,yakym introduced the following bill2   
which was referred to the ,committee on 
,ways and ,means  ,a ,,bill  ,to amend  
the ,internal ,revenue ,code of #aihf to
 reduce certain tax compliance burdens  
with respect to digital asset ownership1
 and for other purposes4  #a4 ,short    
title2 etc  7a7 ,short title ,this ,act 
may be cited as the ,less ,tax          
,paperwork for ,digital ,asset ,owners  
,act4  7b7 ,references ,except as       
otherwise expressly provided1 whenever  
in this ,act an amendment or repeal is  
expressed in terms of an amendment to1  
or repeal of1 a section or other        
provision1 the reference shall be       
considered to be made to a section or   
other provision of the ,internal        
,revenue ,code of #aihf4  7c7 ,table of 
contents ,the table of contents for this
 ,act is as follows3 ,sec4 #a4 ,short   
title2 etc4 ,sec4 #b4 ,treatment of de  

minimis digital asset network fees4     
,sec4 #c4 ,simplified accounting for    
gain and loss on widely traded digital  
assets4 ,sec4 #d4 ,treatment of ,u4,s4  
dollar stablecoin transactions4 ,sec4   
#e4 ,broker requirements4 ,sec4 #f4     
,definitions4  #b4 ,treatment of de     
minimis digital asset network fees  7a7 
,in general ,part ,,iii of subchapter ,o
 of chapter #a of subtitle ,a is amended
 by inserting after section #ajdc the   
following new section3  #ajdd4 ,de      
minimis network fee exception  7a7 ,in  
general ,no gain or loss shall be       
recognized on the disposition of a      
digital asset in payment of a de minimis
 network fee4  7b7 ,de minimis network  
fee ,for purposes of this section--     
7#a7 ,in general ,the term de minimis   
network fee means an amount paid or     
incurred in a digital asset transaction 
to validate another digital asset       
transaction if the aggregate amount so  
paid or incurred with respect to the    
validation of such other digital asset  

transaction does not exceed #aj4  7#b7  
,network fee ,the term network fee means
 any amount which would be a de minimis 
network fee if paragraph 7#a7 were      
applied without regard to the dollar    
limitation specified therein4  7c7      
,disposition of digital asset used ,to  
pay network fee  ,for purposes of this  
section-- 7#a7 a disposition of a       
digital asset shall not fail to be      
treated as a payment merely because such
 asset is not received by another       
person1 and  7#b7 any payment of a      
network fee using a digital asset shall 
be treated as a disposition of such     
asset in exchange for consideration     
equal to the fair market value of such  
digital asset4  7d7 ,treatment of       
unrecognized gain ,the amount of any    
network fee which would otherwise be    
taken into account in determining the   
amount of gain or loss on the           
disposition of any asset1 in determining
 the amount of any deduction1 or in     
determining the basis of any asset      

acquired1 shall be reduced by the amount
 of any gain not recognized by reason of
 subsection 7a7 with respect to the     
disposition of the digital asset used to
 pay such network fee4  7e7 ,exclusions 
7#a7 ,trade or business  7,a7 ,in       
general ,subsection 7a7 shall not apply 
to the disposition of a digital asset   
by--  7i7 a trader1 broker1 or dealer in
 digital assets1  7ii7 a person in the  
trade or business of batching or        
facilitating the validation of digital  
asset transactions on behalf of others1 
7iii7 to the extent provided by the     
,secretary1 any person in a trade or    
business which is substantially similar 
to a trade or business described in     
clause 7i7 or 7ii71 or  7iv7 any person 
that engaged in more than #e1jjj digital
 asset transactions during the preceding
 taxable year4  7,b7 ,administrative    
convenience exception  7i7 ,in general  
,subparagraph 7,a7 shall not apply to   
any taxpayer that demonstrates to the   
,secretary that such taxpayer is of a   

type with respect to which not applying 
subparagraph 7,a7 will not result in a  
substantial ,federal revenue loss4  7ii7
 ,guidance ,the ,secretary shall issue  
guidance that--  7,i7 identifies        
different types of taxpayers with       
respect to which not applying           
subparagraph 7,a7 will not result in    
substantial ,federal revenue loss1 and  
7,,ii7 specifies with respect to each   
such type of taxpayer the information   
that such taxpayer must provide to make 
the demonstration described in clause   
7i74  7iii7 ,certain factors required to
 be taken into account ,the guidance    
issued by the ,secretary under clause   
7ii7 shall-- 7,i7 for purposes of       
determining the classification of types 
of taxpayers1 and whether any ,federal  
revenue loss from not applying          
subparagraph 7,a7 with respect to any   
such type of taxpayer would be          
substantial1 take into account the      
method or methods used by such type of  
taxpayer for selecting the digital      

assets used to pay network fees and the 
average holding period of such digital  
assets by such type of taxpayer1 and    
7,,ii7 determine ,federal revenue loss  
by reducing such loss by a reasonable   
approximation of the additional         
administrative costs of the ,department 
of the ,treasury1 and the additional    
compliance costs of such type of        
taxpayer 7and any person who would be   
required to make additional information 
return reporting with respect to such   
type of taxpayer71 which would be       
imposed if subparagraph 7,a7 did not    
apply to such type of taxpayer4  7#b7   
,certain accounting methods ,subsection 
7a7 shall not apply to any digital      
asset--  7,a7 to which section #dge1    
#ajea7;a71 or #abef7;a71 or  7,b7 except
 as otherwise provided by the           
,secretary1 to which a mark-to-market   
method applies under any other provision
 of this subtitle4  7f7 ,regulations    
,the ,secretary shall issue such        
regulations or other guidance as may be 

necessary or appropriate to carry out   
the purposes of this section1 including 
regulations or guidance to prevent the  
abuse of this section through-- 7#a7    
transaction structuring for the purpose 
of qualifying for the exclusion provided
 in subsection 7a71 and  7#b7 the       
receipt of any value other than the     
validation of a digital asset           
transaction in exchange for a network   
fee4  4  7b7 ,clerical amendment ,the   
table of sections for part ,,iii of     
subchapter ,o of chapter #a of subtitle 
,a is amended by inserting after the    
item relating to section #ajdc the      
following new item3  ,sec4 #ajdd4 ,de   
minimis network fee exception4  4  7c7  
,effective date ,the amendments made by 
this section shall apply to the         
disposition of assets after ,december   
#ca1 #bjbg4  #c4 ,simplified accounting 
for gain and loss on widely traded      
digital assets  7a7 ,in general ,part   
,,iv of subchapter ,o of chapter #a of  
subtitle ,a is amended by inserting     

before section #ajeb the following new  
section3  #ajea4 ,election to apply     
simplified accounting for gain and loss 
on widely traded digital assets  7a7 ,in
 general ,in the case of any designated 
type of digital asset with respect to   
any taxpayer for any taxable year-- 7#a7
 such taxpayer shall recognize gain on  
such designated type of digital asset   
for such taxable year equal to the      
excess 7if any7 of--  7,a7 the sum of-- 
7i7 the aggregate amount realized by the
 taxpayer on sales or exchanges         
7including nonrecognition transactions7 
of widely traded digital assets of such 
designated type during such taxable     
year1  7ii7 in the case of dispositions 
7including nonrecognition transactions71
 other than sales or exchange described 
in clause 7i71 of widely traded digital 
assets of such designated type1 the fair
 market value of such widely traded     
digital assets 7determined as of the    
time of such dispositions71 and  7iii7  
the fair market value of widely traded  

digital assets of such designated type  
held by such taxpayer as of the close of
 the taxable year1 over  7,b7 the sum   
of-- 7i7 the fair market value of       
consideration provided by the taxpayer  
for the acquisition of widely traded    
digital assets of such designated type  
during the taxable year1  7ii7 in the   
case of any disposition described in    
subparagraph 7,a77ii71 any amounts which
 would have reduced the amount realized 
by the taxpayer on such disposition if  
such disposition had been a sale or     
exchange1  7iii7 in the case of the     
acquisition of widely traded digital    
assets of such designated type during   
the taxable year the basis of which in  
the hands of the taxpayer are determined
 by reference to the basis of such      
assets in the hands of the transferor1  
the basis of such assets in the hands of
 the taxpayer immediately after such    
acquisition1 and  7iv7 the fair market  
value of widely traded digital assets of
 such designated type held by such      

taxpayer as of the close of the         
preceding taxable year1  7#b7 such      
taxpayer shall recognize loss on such   
designated type of digital asset for    
such taxable year equal to the excess   
7if any7 of--  7,a7 the amount described
 in paragraph 7#a77;,b71 over  7,b7 the 
amount described in paragraph 7#a77;,a71
 and  7#c7 except as provided in        
paragraph 7#a7 and 7#b71 such taxpayer  
shall not recognize any gain or loss on 
the disposition of widely traded digital
 assets of such designated type4  7b7   
,designated type of digital asset ,for  
purposes of this section--  7#a7 ,in    
general ,the term designated type of    
digital asset means1 with respect to any
 taxpayer for any taxable year1 any type
 of widely traded digital asset with    
respect to which such taxpayer elects   
the application of this section for such
 taxable year4  7#b7 ,type of widely    
traded digital asset ,widely traded     
digital assets shall be treated as being
 of the same type if1 and only if--     

7,a7 such assets are fungible1 or  7,b7 
such assets are determined under rules  
provided by the ,secretary to have      
values that are directly linked or      
highly correlated4  7c7  ,gain or loss  
treated as short-,term  ,any gain or    
loss determined under subsection 7a7    
shall be treated as short-term capital  
gain or short-term capital loss1        
respectively4  7d7 ,treatment of lending
 transactions  7#a7 ,certain lending    
agreements ,in the case of any transfer 
of widely traded digital assets to which
 section #ajeh7;a7 applies1 such assets 
shall be treated for purposes of this   
section as continuing to be held by the 
transferor4  7#b7 ,other lending        
transactions ,in the case of any loan of
 widely traded digital assets which is  
not described in paragraph 7#a71 except 
as otherwise provided by the ,secretary1
 such assets shall be treated for       
purposes of this section as continuing  
to be held by the lender4  7e7 ,election
  7#a7 ,application of election ,an     

election under this section with respect
 to any designated type of digital asset
 shall apply to the first taxable year  
which begins after the date on which the
 taxpayer makes such election and to    
each taxable year thereafter unless     
revoked as provided in paragraph 7#c74  
7#b7 ,partnerships and ,s corporations  
,in the case of any partnership or ,s   
corporation1 the election under this    
section shall be made at the partnership
 or ,s corporation level4  7#c7         
,revocation  7,a7 ,in general ,a        
taxpayer may revoke an election under   
this section with respect to a taxable  
year which-- 7i7 has not begun as of the
 date on which such taxpayer requests   
such revocation1 and  7ii7 is not one of
 the first #e taxable years to which    
such election applies4  7,b7 ,deemed    
revocation ,in the case of any          
designated type of digital asset which  
has ceased to be a widely traded digital
 asset1 the election under this section 
with respect to such designated type    

shall be treated as revoked with respect
 to the first taxable year beginning    
after the date on which such designated 
type ceases to be a widely traded       
digital asset4  7,c7 #e-year waiting    
period ,in the case of any revocation   
under this paragraph with respect to any
 designated type of digital asset1 the  
taxpayer may not make an election under 
this section with respect to such       
designated type if such election would  
apply to any of the first #e taxable    
years to which such revocation applies4 
7,d7 ,special rule for traders making   
mark-to-market election ,if a taxpayer  
has in effect one or more elections     
under this section with respect to      
designated types of digital assets and  
such taxpayer makes the election under  
section #dge7;f77#c7 with respect to any
 taxable year1 the taxpayer shall       
7notwithstanding subparagraph 7,a77 be  
treated as revoking all such elections  
under this section beginning with such  
taxable year4  7f7 ,transition rules    

related to election1 revocation1 and    
certain transfers  7#a7 ,transition rule
 for election ,in the case of an        
election under this section1 with       
respect to any designated type of       
digital asset1 any widely traded digital
 assets of such designated type held by 
the taxpayer shall be treated as sold   
for fair market value on the last day of
 the taxable year preceding the first   
taxable year to which such election     
applies4  7#b7 ,transition rule for     
revocation ,in the case of a revocation 
of an election under this section1      
proper adjustment shall be made in the  
amount of any gain or loss subsequently 
realized for gain or loss taken into    
account under subsection 7a74  7#c7     
,transition rule for certain transfers  
,in the case of any transfer of a widely
 traded digital asset which is a        
designated type of digital asset with   
respect to the transferor for the       
taxable year in which the transfer      
occurs1 if the basis of such asset in   

the hands of the transferee is          
determined by reference to the basis of 
such asset in the hands of the          
transferor1 the basis of such asset in  
the hands of the transferor 7solely for 
purposes of determining the basis of    
such asset in the hands of the          
transferee7 shall be treated as being   
equal to the fair market value of such  
asset at the time of such transfer4  7g7
 ,coordination with certain other       
provisions  7#a7 ,determined without    
regard to wash and constructive sale    
rules ,sections #ajia and #abei shall   
not apply to any transaction with       
respect to which gain or loss is not    
recognized by reason of subsection      
7a77#c74  7#b7 ,coordination with       
related party transaction rules ,section
 #bfg shall not apply with respect to a 
sale or exchange of property if the     
transferor has an election in effect    
under this section for the taxable year 
with respect to such property4  7#c7    
,nonrecognition provisions to not apply 

,in the case of any transfer of a widely
 traded digital asset which is not a    
designated type of digital asset with   
respect to the transferor for the       
taxable year of the transferor in which 
the transfer occurs but which is a      
designated type of digital asset with   
respect to the transferee for the       
taxable year of the transferee in which 
the transfer occurs1 if the transferor  
and transferee are described in section 
#bfg7;b7 7applied without regard to     
section #bfg7;c77#c77 or section        
#gjg7;b77#a71 gain or loss shall be     
recognized on such transfer             
notwithstanding any other provision of  
this title4  7h7 ,clarification that    
certain transfers are treated as        
dispositions ,the following shall not   
fail to be treated as a disposition for 
purposes of this section3 7#a7 ,the     
distribution of any digital asset from a
 trust to a beneficiary4  7#b7 ,the     
transfer of any digital asset from a    
decedent 7whether or not incident to the

 decedent's death74  7i7 ,regulatory    
authority ,the ,secretary shall         
prescribe such regulations or other     
guidance as may be necessary or         
appropriate to carry out the purposes of
 this section1 including regulations or 
guidance relating to--  7#a7 the form   
and manner of making an election or     
revocation under this section1  7#b7    
adjustments necessary by reason of such 
election or revocation1  7#c7           
adjustments to reporting requirements   
relating to widely traded digital assets
 with respect to which an election is in
 effect under this section1  7#d7 the   
treatment of a derivative of a          
designated type of digital asset1 and   
7#e7 preventing abuse of this section4  
4  7b7 ,clerical amendment ,the table of
 sections for part ,,iii of subchapter  
,o of chapter #a of subtitle ,a is      
amended by inserting before the item    
relating to section #ajeb the following 
new item3  ,sec4 #ajea4 ,election to    
apply simplified accounting for gain and

 loss on widely traded digital assets4  
4  7c7 ,effective date ,the amendments  
made by this section shall apply to     
taxable years beginning after ,december 
#ca1 #bjbg4  #d4 ,treatment of ,u4,s4   
dollar stablecoin transactions  7a7 ,in 
general ,part ,,iv of subchapter ,o of  
chapter #a of subtitle ,a is amended by 
redesignating section #ajfc as section  
#ajfd and by inserting after section    
#ajfb the following new section3  #ajfc4
 ,certain ,u4,s4 dollar stablecoin      
transactions  7a7 ,treatment of         
acquisitions of ,u4,s4 dollar           
stablecoins  7#a7 ,determination of     
basis ,the basis of any qualified ,u4,s4
 dollar stablecoin acquired by a        
taxpayer in any sale or exchange shall  
be the redemption value of such         
stablecoin4 ,the preceding sentence     
shall not apply if it is unreasonable   
under the facts and circumstances to    
conclude that the value of the          
consideration provided for such         
stablecoin in such sale or exchange is  

not less than #ii4e percent of such     
redemption value4  7#b7 ,treatment of   
consideration provided in exchange ,for 
purposes of this title1 in the case of  
any consideration other than money      
provided in exchange for a qualified    
,u4,s4 dollar stablecoin1 the income1   
gain1 or loss resulting from the        
provision of such consideration shall be
 determined by treating the value of    
such qualified ,u4,s4 dollar stablecoin 
as being equal to the redemption value  
of such stablecoin4 ,the preceding      
sentence shall not apply if it is       
unreasonable under the facts and        
circumstances to conclude that the value
 of such stablecoin is not less than    
#ii4e percent1 and not more than #ajj4e 
percent1 of such redemption value4  7b7 
,treatment of sale or exchange of       
qualified ,u4,s4 dollar stablecoins     
7#a7 ,determination of gain or loss ,if 
the taxpayer's basis in any qualified   
,u4,s4 dollar stablecoin was determined 
under subsection 7a77#a71 gain or loss  

on such taxpayer's sale or exchange of  
such stablecoin shall be determined as  
though such stablecoin were sold or     
exchanged for the redemption value of   
such stablecoin4 ,the preceding sentence
 shall not apply if it is unreasonable  
under the facts and circumstances to    
conclude that the value of the          
consideration received for such         
stablecoin in such sale or exchange is  
not more than #ajj4e percent of such    
redemption value4  7#b7 ,treatment of   
consideration received in exchange ,for 
purposes of this title1 in the case of  
any consideration other than money      
received in exchange for a qualified    
,u4,s4 dollar stablecoin1 the cost of   
7and amount paid or incurred for7 such  
consideration shall be determined by    
treating the value of such qualified    
,u4,s4 dollar stablecoin as being equal 
to the redemption value of such         
stablecoin4 ,the preceding sentence     
shall not apply if it is unreasonable   
under the facts and circumstances to    

conclude that the value of such         
stablecoin is not less than #ii4e       
percent1 and not more than #ajj4e       
percent1 of such redemption value4  7c7 
,exceptions  7#a7 ,in general           
,subsections 7a7 and 7b7 shall not apply
 with respect to any taxpayer for any   
taxable year if such taxpayer is-- 7,a7 
a trader1 broker1 or dealer in qualified
 ,u4,s4 dollar stablecoins1  7,b7 to the
 extent provided by the ,secretary1 any 
person in a trade or business which is  
substantially similar to a trade or     
business described in subparagraph 7,a71
 or  7,c7 any other person who in the   
preceding taxable year engaged in more  
than #e1jjj transactions to which       
subsection 7a7 or 7b7 applied1          
determined without regard to--  7i7 any 
such transaction which is predominantly 
with respect to a trade or business     
7other than a trade or business         
described in subparagraph 7,a7 or 7,b771
 including the acceptance of qualified  
,u4,s4 dollar stablecoins at redemption 

value as a payment for goods or services
 in such trade or business and the use  
of qualified ,u4,s4 dollar stablecoins  
at redemption value to acquire goods and
 services for use in such trade or      
business1 and  7ii7 any such transaction
 which is a sale 7for money7 of a       
qualified ,u4,s4 dollar stablecoin at or
 below redemption value4  7#b7          
,functional currency other than the     
dollar ,subsections 7a7 and 7b7 shall   
not apply to any taxpayer or qualified  
business unit 7as defined in section    
#ihi7;a77 that uses a functional        
currency other than the dollar4  7#c7   
,related parties ,in the case of any    
sale or exchange between persons        
described in section #bfg7;b7 7applied  
without regard to section #bfg7;c77#c77 
or section #gjg7;b77#a7--  7,a7         
subsections 7a77#a71 7a77#b71 and       
7b77#b7 shall be applied by substituting
 #ajj percent for #ii4e percent1 and    
7,b7 subsections 7a77#b71 7b77#a71 and  
7b77#b7 shall be applied by substituting

 #ajj percent for #ajj4e percent4  7d7  
,redemption value ,for purposes of this 
section1 the term redemption value      
means1 with respect to a qualified      
,u4,s4 dollar stablecoin1 the dollar    
amount for which the issuer is obligated
 to convert1 redeem1 or repurchase such 
stablecoin4  7e7 ,regulations ,the      
,secretary shall issue such regulations 
or other guidance as may be necessary or
 appropriate to carry out the purposes  
of this section1 including regulations  
or other guidance-- 7#a7 describing the 
factors considered1 and documentation or
 substantiation required1 with respect  
to the facts and circumstances tests    
described in subsections 7a77#a71       
7a77#b71 7b77#a71 and 7b77#b71  7#b7    
providing for the application of        
subsection 7c77#a7 with respect to a    
portion of a taxable year if the        
taxpayer only regularly purchases1      
exchanges1 or sells qualified ,u4,s4    
dollar stablecoins for profit for a     
portion of such taxable year1 and  7#c7 

to prevent abuse of this section4  4    
7b7 ,clerical amendment ,the table of   
sections for part ,,iv of subchapter ,o 
of chapter #a of subtitle ,a is amended 
by redesignating the item relating to   
section #ajfc as an item relating to    
section #ajfd and by inserting after the
 item relating to section #ajfb the     
following new item3  ,sec4 #ajfc4       
,certain ,u4,s4 dollar stablecoin       
transactions4  4  7c7 ,effective date   
,the amendments made by this section    
shall apply to taxable years beginning  
after ,december #ca1 #bjbf4  #e4 ,broker
 requirements  7a7 ,in general  7#a7    
,exception for qualified ,u4,s4 dollar  
stablecoins acquired at redemption value
 ,section #fjde7;g77#c77;,d7 is amended 
to read as follows3  7,d7 ,specified    
digital asset ,the term specified       
digital asset means any digital asset   
other than a qualified ,u4,s4 dollar    
stablecoin the customer's basis in which
 at the time of acquisition is at least 
#ii4e percent of such stablecoin's      

redemption value 7as defined in section 
#ajfc7;e774  4  7#b7 ,conforming        
amendments  7,a7 ,section               
#fjde7;c77#a77;,d7 is amended by        
striking digital assets and inserting   
specified digital assets4  7,b7         
,subparagraph 7,b77iv7 and subparagraph 
7,c77iii7 of section #fjde7;g77#c7 are  
each amended by striking digital asset  
and inserting specified digital asset4  
7,c7 ,section #fjej;,i7d77#c7 is amended
 by striking 7as defined in section     
#fjde7;g77#c77;,d774  7b7 ,special rules
 for digital assets used ,to pay de     
minimis validation fee ,section         
#fjde7;g7 is amended by adding at the   
end the following new paragraph3  7#g7  
,special rules for digital assets used  
to pay de minimis validation fee  7,a7  
,in general  ,except as otherwise       
provided by the ,secretary1 in the case 
of the disposition of a digital asset   
with respect to which no gain or loss is
 recognized by reason of section        
#ajdd7;a7--  7i7 except as provided in  

clause 7ii71 subsection 7a7 shall not   
apply to such disposition1 and  7ii7 the
 broker shall include in a return under 
subsection 7a7 such aggregate           
information relating to such            
dispositions of the taxpayer as the     
,secretary determines necessary or      
appropriate1 including for purposes of  
verifying the taxpayer's basis in       
digital assets held by the taxpayer4    
7,b7  ,application of de minimis        
exception  ,if the broker has been      
notified by the taxpayer or the         
,secretary that the exception described 
in section #ajdd7;e77#a77;,b7 applies to
 such taxpayer1 the broker may treat    
such exception as continuing to apply   
with respect to such taxpayer for any   
calendar year 7hereafter in this        
subparagraph referred to as the current 
calendar year7 unless--  7i7 such       
taxpayer had more than #e1jjj digital   
asset transactions with such broker     
during any of the #e preceding calendar 
years and the taxpayer has not notified 

the broker that such exception applies  
to such taxpayer for the current        
calendar year1  7ii7 such taxpayer or   
the ,secretary notifies such broker that
 such exception does not apply to such  
taxpayer1 or  7iii7 such broker         
otherwise knows1 or has reason to know1 
that such exception does not apply to   
such taxpayer4  4  7c7 ,special rules   
for simplified accounting for widely    
traded digital assets ,section          
#fjde7;g71 as amended by subsection 7b71
 is amended by adding at the end the    
following new paragraph3  7#h7 ,special 
rules for simplified accounting for     
widely traded digital assets  7,a7 ,in  
general ,except as otherwise provided by
 the ,secretary1 in the case of widely  
traded digital assets with respect to   
which an election under section #ajea   
applies--  7i7 except as provided in    
clause 7ii71 subsection 7a7 shall not   
apply to dispositions of such assets1   
and  7ii7 the broker shall include in a 
return under subsection 7a7 such        

information with respect to each        
desginated type of such assets 7within  
the meaning of section #ajea7 as the    
,secretary may provide1 including--     
7,i7 aggregate reporting with respect to
 sales1 exchanges1 dispositions1 and    
acquistions of assets of such designated
 type 7including net gain or loss       
thereon71  7,,ii7 the fair market value 
of assets of such designated type held  
by the taxpayer as of the beginning and 
end of the calendar year1 and  7,,iii7  
such other information as the ,secretary
 may require with respect to assets of  
such designated type for purposes of the
 administration of section #ajea4  7,b7 
,determination of election based on     
broker notification ,for purposes of    
subparagraph 7,a71 the broker shall take
 into account any election under section
 #ajea 7and any revocation of such      
election7 if 7and only if7 the taxpayer 
or the ,secretary notifies such broker  
of such election 7or revocation7 or such
 broker otherwise knows1 or has reason  

to know1 of such election 7or           
revocation74  4  7d7 ,effective date    
,the amendments made by this section    
shall apply to returns required to be   
filed1 and statements required to be    
furnished1 after ,december #ca1 #bjbg4  
#f4 ,definitions ,section #ggja is      
amended--  7#a7 by redesignating        
subsection 7p7 as subsection 7q71 and   
7#b7 by inserting after subsection 7o7  
the following new subsection3  7p7      
,definitions related to digital assets  
,for purposes of this title-- 7#a7      
,digital asset ,the term digital asset  
means1 except as otherwise provided by  
the ,secretary1 any digital             
representation of value which is        
recorded on a cryptographically secured 
distributed ledger or any similar       
technology as specified by the          
,secretary4  7#b7 ,traded digital asset 
,the term traded digital asset means1   
except as otherwise provided by the     
,secretary to prevent abuse1 any digital
 asset if-- 7,a7 such asset is fungible1

  7,b7 quotations of such asset are     
readily available on an exchange 7or1 in
 the case of an exchange that does not  
provide quotations1 such quotations are 
readily ascertainable71 and  7,c7 such  
asset is either--  7i7 not a tokenized  
digital asset1 or  7ii7 a wrapped       
digital asset with respect to which the 
reference digital asset is a traded     
digital asset4  7#c7 ,widely traded     
digital asset  7,a7 ,in general ,the    
term widely traded digital asset means1 
with respect to any taxpayer for any    
taxable year and except as otherwise    
provided by the ,secretary to prevent   
abuse1 any traded digital asset if-- 7i7
 quotations for such asset were readily 
available on an exchange for the entire 
calendar year which ends in or with the 
taxable year preceding such taxable     
year1  7ii7 the market capitalization of
 such asset exceeded #ejj1jjj1jjj at    
substantially all times during such     
calendar year1 and  7iii7 not more than 
#aj percent of the units of such asset  

were owned1 directly or indirectly1 by  
the taxpayer or any person described    
with respect to the taxpayer under      
section #bfg7;b7 7applied without regard
 to section #bfg7;c77#c77 or section    
#gjg7;b77#a7 at any time during such    
taxable year or such preceding taxable  
year4  7,b7 ,special rule for wrapped   
digital assets ,in the case of any      
wrapped digital asset1 except as        
otherwise provided by the ,secretary to 
prevent abuse1 such asset shall be      
treated as a widely traded digital asset
 if1 and only if1 the reference digital 
asset with respect to such wrapped      
digital asset is a widely traded digital
 asset4  7,c7 ,authority to ensure      
reliable price discovery ,for purposes  
of subparagraphs 7,a7 and 7,b71 the term
 prevent abuse includes the exclusion of
 assets that lack reliable price        
discovery or that the ,secretary        
determines are at risk of price         
manipulation4  7,d7 ,authority to adjust
 requirements ,the ,secretary may1 by   

regulation1 provide requirements that   
apply in lieu of one or more of the     
requirements of clauses 7i7 through     
7iii7 of subparagraph 7,a7 if the       
,secretary determines that due to       
changes in market conditions 7including 
by reason of the enactment of ,federal  
digital asset market structure          
legislation7 that such alternative      
requirements would more effectively or  
efficiently identify traded digital     
assets for which there is consistent and
 reliable price discovery4  7,e7        
,inflation adjustment ,in the case of   
any calendar year after #bjbg1 the      
#ejj1jjj1jjj amount in subparagraph     
7,a77ii7 shall be increased by an amount
 equal to--  7i7 such dollar amount1    
multiplied by  7ii7 the cost-of-living  
adjustment determined under section     
#a7;f77#c7 for such calendar year1      
determined by substituting calendar year
 #bjbf for calendar year #bjaf in       
subparagraph 7,a77ii7 thereof4  ,any    
increase determined under the preceding 

sentence which is not a multiple of     
#ajj1jjj shall be rounded to the nearest
 multiple of #ajj1jjj4  7#d7 ,tokenized 
digital asset ,the term tokenized       
digital asset means any digital asset   
7other than any qualified ,u4,s4 dollar 
stablecoin7 if more than an             
insignificant portion of the value of   
such digital asset is related to        
anything other than the operation of the
 cryptographically secured distributed  
ledger on which such digital asset is   
recorded4  7#e7 ,wrapped digital asset  
,the term wrapped digital asset means1  
except as otherwise provided by the     
,secretary to prevent abuse1 any digital
 asset if such asset--  7,a7 is         
redeemable on demand1 on a one-for-one  
basis1 for another digital asset1 and   
7,b7 is recorded on a cryptographically 
secured distributed ledger other than   
the cryptographically secured           
distributed ledger on which the digital 
asset referred to in subparagraph 7,a7  
is recorded4  7#f7 ,reference digital   

asset  7,a7 ,in general ,the term       
reference digital asset means1 with     
respect to any wrapped digital asset1   
the digital asset referred to in        
paragraph 7#e77;,a74  7,b7 ,special rule
 for rewrappings ,if1 but for this      
subparagraph1 the reference digital     
asset with respect to any wrapped       
digital asset would be a wrapped digital
 asset 7hereafter referred to in this   
paragraph as the lower-tier wrapped     
digital asset7--  7i7 subparagraph 7,a7 
shall be applied with respect to such   
lower-tier wrapped digital asset1 and   
7ii7 the reference digital asset with   
respect to such lower-tier wrapped      
digital asset shall be treated as the   
reference digital asset of such wrapped 
digital asset4  7,c7 ,multiple wrappings
 ,if1 after the application of          
subparagraph 7,b71 the reference digital
 asset with respect to the lower-tier   
wrapped digital asset is a wrapped      
digital asset1 such subparagraph shall  
be reapplied by treating such lower-tier

 wrapped digital asset as the wrapped   
digital asset4  7#g7 ,stablecoin  7,a7  
,qualified ,u4,s4 dollar stablecoin ,the
 term qualified ,u4,s4 dollar stablecoin
 means any ,u4,s4 dollar stablecoin     
which is issued by--  7i7 a permitted   
payment stablecoin issuer 7as defined in
 section #b7bc7 of the ,,genius ,act1 as
 in effect on the date of the enactment 
of this paragraph71 or  7ii7 a foreign  
payment stablecoin issuer 7as defined in
 section #b7ab7 of the ,,genius ,act1 as
 so in effect7 which is permitted under 
such ,act 7as so in effect7 to offer1   
sell1 or otherwise make available such  
,u4,s4 dollar stablecoin in the ,united 
,states4  7,b7 ,u4,s4 dollar stablecoin 
,the term ,u4,s4 dollar stablecoin means
 a payment stablecoin as defined in     
section #b7bb7 of the ,,genius ,act 7as 
in effect on the date of the enactment  
of this paragraph7 applied by           
substituting dollars for monetary value 
each place it appears in such section4  
7,c7 ,publication of list ,the          

,secretary shall1 to the extent         
feasible1 regularly publish a list of   
qualified ,u4,s4 dollar stablecoins4    
7,d7 ,limited authority to treat        
stablecoins as money ,the ,secretary may
 issue such regulations or other        
guidance as may be necessary or         
appropriate to 7except as otherwise     
expressly provided in this title7-- 7i7 
treat qualified ,u4,s4 dollar           
stablecoins as dollars1 and  7ii7 treat 
other stablecoins as currency if such   
treatment would increase ,federal       
revenues4  7#h7 ,digital asset          
transaction ,the term digital asset     
transaction means any transfer of a     
digital asset recorded on the           
cryptographically secured distributed   
ledger 7or similar technology7 referred 
to in paragraph 7#a74  7#i7 ,validation 
,the term validate1 and any derivative  
of such term 7including validation71    
when used in connection with a digital  
asset transaction1 includes the         
processes of proposing transactions for 

validation and verifying the validation 
of transactions4  4