# 119-s-2207: A bill to amend the Internal Revenue Code of 1986 to reform the treatment of digital assets.

119-s-2207, A bill to amend the Internal Revenue Code of 1986 to reform the treatment of digital assets., is a 119th Congress bill sponsored by Sen. Lummis, Cynthia M. [R-WY] (R-WY); status introduced; PRIA reads it as touching household money (as of 2025-12-21).

- Canonical: https://policyrisk.com/legislation/119-s-2207
- As of: 2025-12-21
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-s-2207
- Congress: 119
- Title: A bill to amend the Internal Revenue Code of 1986 to reform the treatment of digital assets.
- Status: introduced
- Introduced: 2025-06-30
- Sponsor: Sen. Lummis, Cynthia M. [R-WY] (R-WY)
- Cosponsors: 3
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2025-12-21

## Summary

**This bill would create a tax framework for digital assets in the Internal Revenue Code.** It would define key crypto terms, change when crypto gains are taxed, and give the Treasury broad authority to write rules on reporting, basis, and related issues. - Households and casual users would get a de minimis exclusion for personal digital-asset purchases used to buy goods or services, but must keep records or separate wallets. The exclusion caps value or loss at $300 per transaction and stops for the year if total gains exceed $5,000. - Dealers, traders, and brokers would face a new "specified assets" regime that includes actively traded digital assets, adds a 30-day wash-sale disallowance, increases broker reporting and basis adjustment rules, and offers a mark-to-market election for dealers. - Miners and validators could defer income from mining and staking until they sell the generated assets, with that income taxed as ordinary income. The bill also explicitly lets donors claim charitable deductions for appreciated actively traded digital assets.

## Cosponsors (3)

- Sen. Blackburn, Marsha [R-TN] (R-TN), 2025-09-02T00:00:00.000Z
- Sen. Cassidy, Bill [R-LA] (R-LA), 2025-09-02T00:00:00.000Z
- Sen. Cornyn, John [R-TX] (R-TX), 2025-12-01T00:00:00.000Z

## Provisions PRIA read

- Charitable crypto donations count: benefit, high. If enacted, actively traded digital assets would be explicitly treated as eligible noncash gifts for the charitable contribution rules. The bill would create a 'qualified appreciated digital asset' category for private foundation contribution rules when the asset is actively traded and is capital g…
- Exclude small crypto purchases: benefit, high. If enacted, this bill would let you exclude small gains or losses when you use crypto to buy goods or services in a personal sale. The exclusion would cap each transaction at $300 for value or $300 for loss. If your total eligible gains in a year exceed $5,000, you could not use the exclusion that…
- New wash-sale rules for crypto: cost, high. If enacted, the bill would expand wash-sale loss disallowance to 'specified assets,' including digital assets as defined by the Treasury. You could not deduct a loss if you bought a substantially identical specified asset within 30 days before or after the sale; the disallowed loss would be added t…
- Delay tax on mining and staking: mixed, medium. If enacted, people who validate digital assets (including miners and stakers) could defer reporting income from validation until they sell or otherwise dispose of the assets. Any income recognized on that later sale would be taxed as ordinary income. The bill would use the recipient's residence to…
- Mark-to-market election for dealers: mixed, medium. If enacted, dealers or traders in specified digital assets could elect section 475 mark-to-market treatment without prior IRS consent. The election would apply for the year made and later years unless the IRS allows revocation. The choice would be limited to actively traded specified assets and wou…
- New tax rules for crypto lending: mixed, medium. If enacted, lenders of digital assets would have to include in gross income the amount they would have earned if they had not lent the asset. The bill requires appropriate basis adjustments to assets subject to lending, including when lent assets are returned. 'Specified asset' would include active…

## Related bills

- 119-s-1071: National Defense Authorization Act for Fiscal Year 2026
- 119-s-4744: Take Care of America’s Veterans Act
- 119-s-1748: Kids Online Safety Act
- 119-s-292: Educational Choice for Children Act of 2025
- 119-s-3752: SAVE America Act
- 119-s-1241: Sanctioning Russia Act of 2025

## Sources
- [119-s-2207 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/2207)

## Related
- [119-s-1071: National Defense Authorization Act for Fiscal Year 2026](https://policyrisk.com/legislation/119-s-1071)
- [119-s-4744: Take Care of America’s Veterans Act](https://policyrisk.com/legislation/119-s-4744)
- [119-s-1748: Kids Online Safety Act](https://policyrisk.com/legislation/119-s-1748)
- [119-s-292: Educational Choice for Children Act of 2025](https://policyrisk.com/legislation/119-s-292)
- [119-s-3752: SAVE America Act](https://policyrisk.com/legislation/119-s-3752)
- [119-s-1241: Sanctioning Russia Act of 2025](https://policyrisk.com/legislation/119-s-1241)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-s-2207 (as of 2025-12-21).