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Virtual Currency Transactions and the Audit Process

Quick Answer

NFT taxation involves four analytical layers: (1) creation and minting — ordinary income when royalty structures trigger; (2) buyer / seller — capital gains typically, but collectibles rate (28%) may apply per Notice 2023-27; (3) royalties — ordinary income to creators; and (4) wash-sale and loss limitations. The short version is that NFTs are generally capital assets but can be collectibles taxed at 28%. In our experience, the collectibles analysis under Notice 2023-27 is where practitioners get tripped up.1

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Four analytical layers for NFT taxation.

The Four NFT Tax Layers

CreationMinting Income
TradeCapital / Collectible
RoyaltiesOrdinary Income
LossesLimitations
NFT tax layers.
Layer Treatment2
Creation / Minting Ordinary income when realized
Buy / Sell Capital gain / loss; collectibles 28%
Royalties Ordinary income to creator
Losses Capital loss limits; worthless treatment

Quick Reference

Jump to: creation, trade, royalties, or losses.

1. NFT Creation and Minting

Minting generally not taxable; first sale triggers ordinary income to creator.

If this is you: Artist minting NFTs. Ordinary income on first sale to buyer. Self-employment tax applies if held in trade or business. Cost of creation typically capitalized.

Creation Tax Strategy

  1. Document creation costs.
  2. Track first sale proceeds.
  3. Recognize income on first sale.
  4. Apply self-employment analysis.
  5. Consider entity formation.

2. Buyer / Seller Capital Treatment

Generally capital gain / loss; collectibles may apply.

If this is you: NFT buyer or seller. Capital gain / loss on sale. Notice 2023-27 analysis: look-through test determines if NFT is collectible. Collectibles taxed at 28% max.

3. Creator Royalties

Smart-contract royalties are ordinary income to creator.

If this is you: Creator receiving automatic royalties via smart contract. Ordinary income on receipt. Self-employment tax consideration. Recognized at FMV when received.

4. Loss Limitations

Capital loss rules apply; worthlessness complicated.

If this is you: Holding NFTs that dropped dramatically. Abandoned / worthless NFT: difficult treatment post-TCJA. $3K annual ordinary offset + carryforward. Sale to unrelated party for nominal amount supports realization.

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NFT Tax Authority Lookup

NFT tax authority.
Authority Purpose
Notice 2023-27 NFT collectibles guidance
Notice 2014-21 Property classification
IRC §408(m) Collectibles definition
Form 8949 Capital gain / loss
Schedule C / SE Business creator income

Found your letter or notice code? The next step is confirming your exact deadline and whether you need representation. A 15-minute call answers both. Book a free call →

NFT Tax Statute

  • 3-year assessment under IRC §6501.
  • 6-year for 25%+ omission.
  • Unlimited for fraud.

NFT Tax Patterns

NFT tax outcomes. Source: Brotman Law practice.
Situation Outcome
Creator — first sale Ordinary + SE tax
Buyer / seller — short-term Ordinary rates
Collectible NFT > 1 year 28% max collectibles rate
Non-collectible > 1 year LTCG 0/15/20%

NFT Audit Escalation

Examination

IDR on NFT transactions and character.

Collectibles Analysis

Notice 2023-27 look-through test.

Adjustment / Appeal

Character and basis disputes.

First 48 Hours

  1. Identify all NFT transactions.
  2. Classify as creator / investor / collector.
  3. Determine collectibles status.
  4. Calculate gain / loss.
  5. Engage counsel for complex matters.
Brotman Law handles NFT and crypto taxation. Based in San Diego.

The ROI Question

28% collectibles vs. 20% LTCG is 8-point swing. Character analysis matters significantly.

When to Engage

  • Material NFT activity.
  • Creator income questions.
  • Collectibles classification.
  • Loss claim evaluation.

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Frequently Asked Questions

How are NFTs taxed?

Four analytical layers — creation / minting, buyer / seller trading, royalties, and losses. NFTs generally property (capital gain / loss); collectibles classification per Notice 2023-27 applies to some NFTs at 28% max rate.

What is Notice 2023-27?

IRS guidance on NFT collectibles classification. Look-through test — if NFT represents ownership of collectible (art, coin, gem, wine), collectibles treatment applies. Otherwise ordinary capital asset.

What is the collectibles tax rate?

28% maximum long-term capital gains rate for collectibles. Compares to 20% regular LTCG max. Short-term collectibles taxed at ordinary rates (same as non-collectibles).

Do NFT creators owe SE tax?

Yes when activity rises to trade or business. Schedule C ordinary income + SE tax. Hobby treatment if not trade or business — ordinary income without SE but limited deductions.

Are smart contract royalties taxable?

Yes. Ordinary income at FMV on receipt. Self-employment tax applies if business activity. Foreign creators may have withholding considerations.

Can I deduct NFT losses?

Yes as capital losses. $3K annual ordinary offset + carryforward. Worthless / abandoned NFT: difficult post-TCJA. Sale to unrelated party for nominal amount supports realization.

Does wash sale rule apply to NFTs?

Currently no, per IRS position (NFTs are property, not securities). Rule could change legislatively. Current-year verification prudent.

What is a collectible NFT?

NFT whose underlying asset would be a collectible under §408(m) — art, coin, stamp, gem, alcoholic beverage. Most art NFTs likely qualify; utility NFTs may not.

How is NFT basis calculated?

Purchase price + gas fees + platform fees. Creator basis: costs of creation if capitalized. Subsequent trades require basis tracking through wallet transactions.

Is minting a taxable event?

Generally no. Minting creates the NFT but no realization. First sale triggers income to creator. Gas fees paid by minter generally capitalize into basis.

What about NFT-to-NFT trades?

Each trade is a taxable disposition. Gain / loss measured by FMV received minus basis surrendered. No like-kind exchange under current law.

Do I report NFTs on 1040 question?

Yes. Digital asset question includes NFTs. “Yes” if you received, sold, exchanged, or disposed of any NFT.

Are NFT drops ordinary income?

Generally yes when received with dominion and control. FMV at receipt is ordinary income, similar to airdrops. Basis = FMV at receipt.

If you have read this far, you have a notice and you are trying to understand it before doing anything that makes it worse. That instinct is correct.

The next right move is a 15-minute call. We will identify the audit type, confirm your deadline, and tell you honestly whether you need representation. There is no cost and no obligation.

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Next Steps

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