Oct. 16, 2023
Dear IRS and Treasury Department, I am writing to express my concerns regarding the proposed regulations outlined in the PDF document titled "Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions." Specifically, I would like to address the issue of poorly defined terms within the proposed regulations. It is noted that the proposed regulations utilize undefined terms, such as "platform," which can be interpreted in various ways. This lack of clarity and specificity can lead to confusion and uncertainty among taxpayers and industry participants. Additionally, terms like "wallet," "smart contracts," and "validator" are defined in a manner that does not accurately reflect their technical meaning. This inaccurate definition further contributes to the potential for misunderstanding and misinterpretation in the application of these regulations. I believe it is crucial to ensure that all terms used in the proposed regulations are clearly defined and accurately reflect their technical meaning. This will provide greater clarity and certainty for taxpayers and industry participants, ultimately resulting in a more effective and fair regulatory framework. Thank you for considering my concerns. I hope that my feedback can contribute to the improvement and refinement of the proposed regulations. Sincerely, Kresimir