USDT as Property: The IRS treats all digital assets, including stablecoins like USDT, as property (Notice 2014-21). Every disposal (payment to supplier) is a taxable event.

Per-Wallet Basis Tracking: Rev. Proc. 2024-28 requires tracking cost basis on a per-wallet/per-account basis starting Jan 1, 2025. Do not pool basis across wallets.

Form 8949 Boxes (2025+): Short-term digital assets use boxes G/H/I. Long-term use J/K/L. Box I = no 1099-DA received. Box L = long-term, no 1099-DA.

FASB ASU 2023-08: Does NOT apply to stablecoins. No fair-value accounting required for USDT.

Form 1099-DA: Starting 2025, brokers report gross proceeds. Starting 2026, cost basis will also be reported. Stablecoin sales under $10,000/year at a single exchange may be reported in aggregate.

Schedule D (Form 1120): C-Corporations report capital gains/losses on Schedule D attached to Form 1120. Form 8949 entries roll up to Schedule D.

PDS Workflow: Buy USDT on Coinbase → Record acquisition (cost basis = USD paid) → Pay supplier with USDT → Record disposal (proceeds = FMV of licenses received) → Gain/Loss = Proceeds − Cost Basis