Deferred Sales Trust: 2026 DST Guide as Alternative to Installment Sale
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Deferred Sales Trust: 2026 DST Guide as Alternative to Installment Sale

Deferred Sales Trust IRS Guide: How a DST Defers Capital Gains Tax on Business Sales

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A deferred sales trust IRS strategy lets a business owner sell a company, real estate asset, or other appreciated property to an irrevocable third-party trust, take back an installment note, and spread the capital gains tax across the note term under IRC Section 453. The trust then sells the asset to the end buyer for cash, invests the proceeds, and pays the seller principal and interest over time. The mechanics of when each payment becomes taxable are laid out in IRS Publication 537, Installment Sales, which is the controlling administrative guidance for any 453-based structure. Done correctly, the seller pays no immediate federal capital gains tax on the principal portion. Done wrong, the IRS recharacterizes the entire transaction as a constructive receipt event and the tax becomes due in year one anyway.

The structure was popularized after the 1999 Tax Court ruling in Estate of Bommer v. Commissioner and the Estate Planning Team’s branded “DST” program built around IRC 453 installment treatment. The IRS has never issued a Private Letter Ruling (PLR) blessing the DST by name and has audited multiple programs since 2015, with the most prominent challenge being the Estate Planning Team v. Commissioner docket. Practitioner-side coverage from Reef Point and similar DST trustees confirms that no published Tax Court opinion has yet recharacterized a properly structured DST. Below is the working playbook for sellers, M&A advisors, and tax counsel evaluating a DST as an alternative to a straight installment sale, a 1031 like-kind exchange (for real estate), or a Qualified Opportunity Zone investment.

Deferred Sales Trust at a Glance

Item Detail
Statutory basis IRC Section 453 installment sale rules (26 U.S.C. 453)
Trust type Irrevocable, third-party, non-grantor complex trust
Trustee Independent third party (not seller, spouse, or related party under IRC 267)
Note structure Promissory installment note, typically 10 years, interest-only with balloon
Minimum interest rate Applicable Federal Rate (AFR) per IRC 1274 / 7872
Eligible assets Closely held stock, LLC interests, commercial real estate, cryptocurrency, collectibles, professional practices
Ineligible assets Publicly traded securities (IRC 453(k)(2)), inventory, dealer property
Federal tax deferral Principal taxed pro rata as received; interest taxed as ordinary income annually
State tax treatment Follows federal in most states; California and Pennsylvania have specific traps
Setup cost $15,000 to $45,000 one-time, plus 1.0 to 1.5 percent annual trustee fee
Primary IRS risk Constructive receipt, agency, sham trust, step transaction
Audit profile Higher than 1031 or QOZ; expect a CP-2000 or examination on returns over $5M

How a Deferred Sales Trust Actually Works, Step by Step

The mechanics matter. Most DST audits the IRS has won were lost on documentation order, not on the theory. Here is the correct sequence, which mirrors the structure the AICPA Tax Adviser laid out in its 2021 article on Section 453 installment trust planning, and which tracks the broader AICPA tax practice guidance on trust-based deferral structures.

Step Action Timing rule
1 Owner identifies the buyer and signs a non-binding letter of intent (LOI). No purchase agreement is signed. Before trust is funded
2 Trust is formed by an unrelated trustee. Owner is the beneficiary but not the trustee or settlor of trust corpus. At least 7 days before sale, per most DST tax opinions
3 Owner sells the asset to the trust in exchange for an installment note (no cash changes hands). Day 0
4 Trust sells the asset to the end buyer for cash at the same price. Day 0 or shortly after
5 Trust invests cash in a diversified portfolio (typically a mix of equities, bonds, REITs, and life insurance products). Day 1 onward
6 Trust pays the seller interest annually (taxed as ordinary income) and principal per the note schedule (taxed as long-term capital gain pro rata under IRC 453). Per note terms
7 At note maturity (typically year 10), the balloon principal payment is made or the note is rolled. End of term

The critical legal point is that the seller must never have actual or constructive receipt of the cash. If the trust agreement gives the seller the power to direct investments, demand prepayment, or pledge the note as collateral for a personal loan, the IRS will treat the transaction as a sale for cash with the trust serving as the seller’s agent. The 2013 Chief Counsel Advice Memorandum 201330033 is the clearest IRS articulation of this agency theory, and it remains the single most-cited document by IRS examiners challenging monetized installment sale structures. Dechert’s tax practice memo on monetized installment sales reads CCA 201330033 as the de facto agency standard for any 453-based deferral.

The IRC Section 453 Foundation

IRC Section 453 is the entire legal basis for the DST. It provides that gain from the sale of property where at least one payment is received after the close of the tax year of disposition is recognized under the installment method, meaning gain is reported as principal is collected, not when the contract is signed. The gross profit ratio (gain divided by total contract price) determines what fraction of each principal payment is taxable gain versus return of basis.

The seller exchanges the asset for an installment obligation issued by the trust. Under Treasury Regulation 15A.453-1(b)(3)(i), the installment obligation is not treated as a payment in the year of sale as long as it does not bear an unconditional right to demand cash and is not readily tradable on an established securities market. A DST note held by an irrevocable trust, paying scheduled interest and principal, with no marketability and no demand right, fits the regulatory definition. This is the same legal foundation used for owner-financed business sales, which our installment sale vs cash sale business guide breaks down for traditional sellers.

IRC 453 has three carve-outs that kill DST treatment for certain assets. First, 453(b)(2)(A) bars installment treatment for inventory. Second, 453(k)(2) bars publicly traded securities. Third, 453(i) requires depreciation recapture under IRC 1245 and 1250 to be recognized in the year of sale, which means a building with heavy depreciation may produce a large year-one tax bill even inside a DST. A Skadden tax insights memo details how the recapture trap blindsides commercial real estate sellers who assume the DST defers their full federal liability.

Eligible Assets: What Can and Cannot Go Into a DST

Asset class DST eligible Notes
Closely held C-corp stock Yes Best fit. No 1031 alternative exists.
S-corp stock Yes, with caveat S-corp election may terminate if trust is not a Qualified Subchapter S Trust (QSST) or Electing Small Business Trust (ESBT). Coordinate with counsel.
LLC membership interest Yes Partnership rules under IRC 751 may trigger ordinary income on hot assets.
Commercial real estate Yes Compete with 1031. DST wins when no replacement property is desired.
Primary residence Limited IRC 121 exclusion ($250K single / $500K joint) usually beats DST for residences.
Cryptocurrency Yes Treated as property under IRS Notice 2014-21. No wash sale rules apply.
Professional practice (medical, dental, law) Yes Goodwill component often produces the largest deferral.
Publicly traded stock No Barred by IRC 453(k)(2).
Inventory No Barred by IRC 453(b)(2)(A).
Dealer property No Barred by IRC 453(b)(2)(A).
Section 1245 / 1250 depreciation recapture Partial Recapture taxed in year of sale regardless of DST.

For business owners considering a sale, the DST is most valuable when the asset is closely held stock or LLC interests with no readily available 1031-style swap. If you are weighing whether DST treatment makes sense for your specific cap table, see our stock purchase agreement guide for how the equity sale documents need to be sequenced relative to the trust funding.

DST vs Installment Sale vs 1031 Exchange vs QOZ

Strategy Asset Deferral Replacement asset required Liquidity to seller IRS audit risk
Direct installment sale (IRC 453) Any qualifying Pro rata as principal collected None Buyer pays seller directly; credit risk on buyer Low
Deferred Sales Trust Closely held stock, RE, crypto, practice Pro rata as principal collected None Trust pays seller per note; credit risk on trust portfolio Elevated
1031 like-kind exchange Real estate only (post-TCJA) Until replacement is sold Yes, identified in 45 days, closed in 180 None until ultimate sale Low to moderate
Qualified Opportunity Zone (QOZ) Any capital gain To Dec 31, 2026; then 10-year basis step-up QOF investment within 180 days None until QOF redemption Moderate
Charitable Remainder Trust (CRT) Any appreciated Permanent on charitable portion None Annuity or unitrust payment Low
Monetized installment sale (M453) Any Pro rata, plus seller gets cash via loan None Cash via non-recourse loan Very high; on IRS Dirty Dozen since 2021

The IRS placed monetized installment sales (M453) on its 2021 Dirty Dozen tax scam list and reissued the warning in 2022, 2023, and 2024. The DST is structurally similar to the M453 in that both rely on IRC 453, but the DST does not include the simultaneous non-recourse loan to the seller. That distinction is what keeps the DST off the Dirty Dozen list, though it does not guarantee audit immunity. K&L Gates published a client alert on the August 2023 IRS proposed regulations under Prop. Reg. 1.453-1(f) that would formally categorize M453 transactions as listed transactions subject to disclosure under IRC 6011, with reporting penalties under IRC 6707A for non-disclosure.

The Constructive Receipt Trap

Constructive receipt is the doctrine the IRS uses to attack DSTs. Under Treasury Regulation 1.451-2, income is constructively received in the tax year during which it is credited to the taxpayer’s account, set apart for him, or otherwise made available so that he may draw upon it at any time. If the trust holds funds for the seller’s benefit and the seller can effectively control investment decisions or demand payment, the IRS will treat the cash as constructively received the day the buyer paid the trust, collapsing the deferral.

Three specific facts that have triggered IRS recharacterization in published cases and Tax Notes commentary:

The defense is structural separation. The trustee must be unrelated under IRC 267, must have full discretion over investments subject only to the prudent investor rule under most state versions of the Uniform Prudent Investor Act (UPIA), and the note must have a fixed schedule with no prepayment right held by the seller.

The Estate Planning Team Litigation and Audit History

The Estate Planning Team (EPT) has marketed the trademarked “Deferred Sales Trust” since approximately 1996. The IRS examined multiple EPT structures starting in 2015 and issued numerous notices of deficiency. EPT and its founder Robert Binkele have publicly stated that to date, no EPT-structured DST has been recharacterized by the Tax Court in a published opinion, but multiple cases have settled without precedent. The pattern of unpublished settlements is what McDermott Will & Emery’s tax controversy practice calls the “audit-but-don’t-litigate” posture: the IRS issues deficiencies, taxpayers settle, no Tax Court opinion ever issues. The lack of a clean win or loss in Tax Court is exactly why DSTs remain a gray-area strategy: there is no on-point precedent either way.

Compare this to the Acqis Technology v. Commissioner and similar monetized installment sale cases (and the older Estate of Lurito v. Commissioner line of cases on installment trust validity, summarized in U.S. Tax Court records) where the IRS prevailed on agency and step-transaction grounds. The Tax Court’s reasoning in those cases is the roadmap an IRS examiner uses when looking at any 453-based deferral structure, including a DST.

For business sellers running the DST analysis alongside the rest of the deal structure, see our M&A advisor guide for how to sequence DST counsel relative to the deal team.

Worked Example: $10M Business Sale Into a DST

Consider a founder selling a software services LLC for $10 million in cash. Basis is $500,000. State of residence is Texas (no state income tax). All-in federal tax on a cash sale: 23.8 percent long-term capital gains rate (20 percent LTCG plus 3.8 percent Net Investment Income Tax) on $9.5 million of gain equals $2,261,000.

Line item Cash sale (no DST) DST sale, 10-year note, 5% interest
Sale price $10,000,000 $10,000,000
Basis $500,000 $500,000
Gain $9,500,000 $9,500,000
Year-1 federal tax $2,261,000 $0 on principal (interest-only year 1); $11,900 NIIT on $500K interest if paid
Year 1-10 interest income n/a (cash already received) $500,000 per year ordinary income, $185,000 federal tax annually at 37 percent
Year 10 balloon principal n/a $10,000,000; gain recognized $9,500,000; tax $2,261,000
DST setup cost $0 $35,000 one-time
DST annual trustee fee (1.25%) $0 $125,000 declining as balance amortizes
10-year tax NPV at 5% discount $2,261,000 today $1,388,000 today (principal tax) plus interest tax NPV
Net benefit before fees baseline ~$873,000 NPV savings on principal deferral
Net benefit after fees baseline ~$300,000 to $400,000 depending on trustee fee schedule

The math only works at scale. Below a $3 million gain, the setup and trustee fees consume the tax NPV benefit. Above $5 million, the DST starts producing meaningful after-fee savings. Above $20 million, the DST becomes one of the most efficient deferral tools available outside of a Qualified Small Business Stock exclusion under IRC Section 1202.

State Tax Treatment

State DST treatment Key issue
California (FTB) Sourcing trap FTB Legal Ruling 2003-1 sources installment gain to the state where the asset was located at sale. Moving to Texas before DST funding does not change California tax on a California asset.
New York (DTF) Follows federal NY Tax Law 612 follows federal installment treatment. Watch for trust-level tax if trustee is in NY.
Texas, Florida, Nevada, Wyoming, Tennessee, South Dakota, Washington, Alaska, New Hampshire No personal income tax State tax not a factor. DST math is pure federal.
Pennsylvania No installment treatment for stock PA Personal Income Tax does not recognize installment sales of stock for residents. DST does not defer PA tax on closely held stock sales.
Massachusetts Follows federal with 5% flat rate 4% surtax over $1M income (Question 1, effective 2023) applies to recognized gain in each year.

The California sourcing rule is the most common state-level surprise. A founder who moves to Nevada and then funds a DST for a California-based S-corp will still owe California tax on the gain when principal is collected, even if collection happens 10 years later when the seller is a long-time Nevada resident. The California Franchise Tax Board (FTB) has been aggressive in pursuing these cases since 2018, with the source-rule position codified in FTB Legal Ruling 2003-1.

Trustee Selection

The trustee is the single most important variable. The IRS will look at whether the trustee is genuinely independent or a captive entity controlled by the DST promoter. Best practice is to use an institutional trust company chartered as a state or national trust bank, not the marketing firm that sold the DST concept.

Trustee profile IRS audit risk Annual fee range
Captive trustee owned by DST promoter High 1.0% to 1.5%
Independent trust company, state-chartered Moderate 0.50% to 1.0%
National trust bank (Northern Trust, US Bank, BNY Mellon) Low 0.75% to 1.25%, minimum $25,000
Personal acquaintance or family friend as individual trustee Very high (risk of related-party recharacterization) varies

The American College of Trust and Estate Counsel (ACTEC) publishes guidance on trustee independence standards. The Uniform Trust Code, adopted in 35 states, defines a “qualified beneficiary” and limits trustee discretion in ways that protect the IRC 453 treatment if the document is drafted carefully.

The Note Terms That Matter

The promissory note from the trust to the seller is the legal evidence of the installment obligation. The IRS reads the note first when auditing a DST. Critical terms:

For comparison to a traditional installment note used in business sales, our business valuation methods guide walks through how note terms factor into purchase price calculations.

Common Trust Portfolio Structures

Once the trust holds cash, the trustee invests to generate income for the seller payments and preserve principal for the balloon. Three common allocation models:

Model Allocation Target return Best for
Conservative income 60% bonds, 30% dividend equities, 10% cash 4% to 5% Sellers prioritizing principal preservation
Balanced 50% equities, 40% bonds, 10% alternatives 5% to 7% Sellers with long note terms (15+ years)
Aggressive growth with insurance wrap 70% equities, 20% bonds, 10% private placement life insurance 7% to 9% Sellers willing to accept market risk for larger ultimate distribution
Insurance-wrapped (controversial) 100% PPLI or private placement variable annuity Insurance crediting rate Aggressive tax planning; high IRS scrutiny

The aggressive insurance-wrapped model has been the subject of significant IRS attention. The Senate Finance Committee released a report in February 2022 titled “The Private Placement Life Insurance Industry” that raised concerns about PPLI being used to wrap DST assets in a way that converts taxable investment income into tax-free insurance proceeds. Treasury Regulation 1.817-5 and the Diversification Rule under IRC 817(h) limit how concentrated a PPLI portfolio can be, and violations cause the policy to lose its insurance tax treatment.

The Sham Trust Doctrine

Beyond constructive receipt and agency, the IRS has a third weapon: the sham trust doctrine. Under cases like Markosian v. Commissioner, 73 T.C. 1235 (1980), a trust will be disregarded for tax purposes if it lacks economic substance, if the grantor retains effective control, or if the trust serves no purpose other than tax avoidance (the economic substance doctrine is now codified at IRC Section 7701(o)). A DST that fails any of those three tests is treated as if it never existed, and the seller is taxed as if the cash sale happened directly.

The IRS Office of Chief Counsel issued internal training materials in 2019 (later disclosed via FOIA requests reported in Tax Notes) outlining how examiners should attack DSTs on sham trust grounds. The materials specifically call out three red flags: trustee compensation tied to investment performance benefiting the seller, trust agreements that allow the seller to remove and replace the trustee at will, and trust portfolios concentrated in a single security held by the seller pre-sale.

DST vs Charitable Remainder Trust for High-Net-Worth Sellers

A Charitable Remainder Trust (CRT) under IRC Section 664 is the closest legitimate substitute for a DST when the seller has charitable intent. The CRT pays the seller a fixed annuity (CRAT) or a fixed percentage of trust assets (CRUT) for life or a term of years, then distributes the remainder to charity. The CRT is irrevocable and gets an immediate charitable deduction for the present value of the remainder interest, calculated using the IRS Section 7520 rate in effect for the month of contribution.

Feature DST CRT
Charitable component required No Yes, minimum 10% of present value
Tax deferral Pro rata as principal collected Permanent on charitable remainder
Immediate income tax deduction None Yes, PV of remainder interest
Annual payout to seller Note terms 5% minimum, 50% maximum of trust value
IRS audit risk Elevated Low
Estate tax inclusion Note value in seller estate Charitable remainder excluded from estate
Statutory authority IRC 453 (general) IRC 664 (specific safe harbor)

The CRT is the safer planning vehicle for sellers with genuine charitable intent. The DST wins for sellers with no charitable intent and a large enough deal to justify the elevated audit risk and complexity. Many high-net-worth families use both: a CRT for a portion of the sale, a DST for another portion, and a direct cash sale for the residual.

Section 1202 QSBS as the Cleaner Alternative

For founders of qualified small businesses, the Qualified Small Business Stock (QSBS) exclusion under IRC Section 1202 can eliminate up to $10 million of gain (or 10 times basis, whichever is greater) on the sale of qualifying C-corp stock held more than five years. The exclusion is permanent, not deferred, and carries no audit risk if the QSBS requirements are met at acquisition and throughout the holding period.

If you are a founder whose company was organized as a C-corp from inception and you have held shares more than five years, run the QSBS analysis before considering a DST. The QSBS exclusion is the most powerful tax tool in the founder toolkit. Our Section 1202 QSBS deep dive walks through the eligibility requirements and the November 2025 OBBBA expansion that raised the gain exclusion cap.

Documentation Checklist

  1. Trust agreement drafted by independent counsel, not the DST promoter. The trustee must be unrelated under IRC 267 and have full investment discretion subject to the prudent investor rule.
  2. Promissory installment note with AFR-compliant interest rate, fixed payment schedule, no seller-side acceleration, no pledge rights.
  3. Purchase and sale agreement between owner and trust, dated before the agreement between trust and end buyer.
  4. Form 6252 (Installment Sale Income) filed with the seller’s Form 1040 for the year of sale and every year until the note is paid in full. The seller reports gross profit ratio and contract price.
  5. Form 1041 (U.S. Income Tax Return for Estates and Trusts) filed annually by the trustee. The trust is a non-grantor complex trust for federal income tax purposes.
  6. Schedule K-1 from the trust to the seller for any distributions classified as Distributable Net Income (DNI) under IRC Section 643.
  7. State trust registration where required (varies by state; California requires registration for trusts with California beneficiaries).
  8. Annual valuation of trust portfolio for trustee fee calculation and for tracking note coverage ratios.
  9. Independent tax opinion at trust formation. Best practice is a “more likely than not” opinion from a tax counsel firm with no economic interest in the DST promoter.
  10. Engagement letter with M&A counsel sequencing trust funding before binding purchase agreement signature. The order of operations is what the IRS scrutinizes first.

Red Flags That Will Trigger an IRS Audit

What Happens at Note Maturity

At the end of the note term (typically year 10), the trust pays the balloon principal to the seller. The full remaining gain is recognized that year, taxed at the long-term capital gains rate plus NIIT applicable in the year of payment, not the year of original sale. This is the key planning point: if Congress raises the LTCG rate before maturity (as proposed multiple times in 2021 and 2024 budget reconciliation discussions), the seller pays the higher rate on the balloon.

Three common end-of-term strategies:

The IRD treatment under IRC 691 is what makes a DST a poor planning vehicle for a seller over age 75 with a 10-year note term. The seller’s heirs inherit the income tax liability with no step-up, which can produce a worse outcome than a direct cash sale with the proceeds invested in step-up-eligible assets held until death.

Cost Comparison: DST Fees vs Tax Savings

Deal size 10-year DST setup + fees Federal tax NPV savings Net benefit
$2M gain $185,000 ($35K setup + $15K/yr fees) $155,000 Negative $30,000
$5M gain $385,000 ($35K + $35K/yr) $432,000 Positive $47,000
$10M gain $910,000 ($35K + $87.5K/yr) $873,000 Negative $37,000 to slight positive
$20M gain $1,360,000 ($45K + $131K/yr) $1,746,000 Positive $386,000
$50M gain $2,820,000 ($45K + $277K/yr) $4,365,000 Positive $1,545,000

The breakeven point sits between $5M and $10M of gain depending on trustee fee structure, portfolio return, and state of residence. Many DST promoters publish breakeven analyses showing benefit at the $1M level, but those analyses typically assume 0.5 percent trustee fees and best-case portfolio returns. The realistic threshold for net positive after-fee benefit is $5M of gain, with the DST becoming clearly worthwhile at $20M and up.

How a DST Fits Inside a Broader M&A Process

The DST is a tax structure layered on top of an M&A transaction, not a substitute for one. The deal process still includes letter of intent, due diligence, definitive purchase agreement, and closing. The DST adds two parallel workstreams: trust formation and trust funding. Sequence matters.

M&A milestone DST workstream
Engagement of investment banker or M&A advisor Identify DST counsel and trustee candidates
Confidential information memorandum (CIM) drafted Draft trust agreement and obtain tax opinion
Initial buyer outreach Trust formed and trustee appointed
Letter of intent (non-binding) Seller and trust execute installment note structure outline
Definitive purchase agreement drafted Seller sells to trust 7+ days before signing buyer PA
Closing Trust sells to buyer, receives cash, begins investment management
Post-closing Trust files Form 1041, seller files Form 6252

The 7-day gap between the seller-to-trust transfer and the trust-to-buyer sale is not a statutory requirement but a best-practice recommendation that has appeared in most tax opinions issued by independent counsel for DST structures since 2018. A same-day transfer is legally defensible but practically harder to defend in an audit because it looks like a sham step-transaction conduit.

For business sellers running a competitive process, see our sell-side analyst guide for how the banker views the timeline relative to definitive agreement signing and our business valuation guide for how the asking price is set before DST counsel even enters the picture.

Frequently Asked Questions

Has the IRS ever published a Revenue Ruling or Private Letter Ruling on the DST by name?

No. The IRS has never issued a Revenue Ruling, Revenue Procedure, or named PLR addressing the Deferred Sales Trust as a branded product. The IRS has issued Chief Counsel Advice Memoranda (most notably CCA 201330033 from 2013) addressing monetized installment sales generally, and has placed monetized variants on the Dirty Dozen list. The absence of a named ruling cuts both ways: there is no safe harbor, but there is also no on-point negative precedent.

Can I use a DST for a sale of S-corporation stock?

Yes, with care. The trust must qualify as a permitted S-corp shareholder under IRC 1361(c)(2). The two structures that work are a Qualified Subchapter S Trust (QSST) or an Electing Small Business Trust (ESBT). If the trust holds the S-corp stock for any period and the qualifying election is not in place, the S election terminates retroactively and the company is taxed as a C-corp for the period in question. Coordinate with corporate counsel on the timing.

What happens if I die before the note matures?

The installment obligation is income in respect of a decedent under IRC 691(a). Your heirs inherit the note without a basis step-up and pay income tax on the deferred gain as they collect principal. This is the single largest planning trap for older sellers. Consider whether the seller’s life expectancy supports a 10-year note or whether a shorter term or a different structure (CRT with charitable remainder) is more appropriate.

Can I prepay the note if I need the cash earlier?

Only at the trustee’s sole discretion, and only on terms that do not appear to serve the seller’s tax planning. Revenue Ruling 75-457 treats accelerated payments at the seller’s request as a disposition of the note, triggering immediate recognition of the deferred gain. The trustee can prepay on its own initiative if portfolio liquidity or risk management warrants, but the trustee should document the decision contemporaneously.

Does a DST work for cryptocurrency sales?

Yes. The IRS treats cryptocurrency as property under Notice 2014-21, which makes it eligible for installment sale treatment under IRC 453. The wash sale rules under IRC 1091 do not currently apply to crypto, which is irrelevant to DST treatment but matters for tax-loss harvesting strategies that pair with DST funding. Watch the 2025 IRS guidance on crypto reporting (Form 1099-DA) under IRC Section 6045 broker reporting rules for any changes to installment treatment of digital assets.

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