IRS_Digital_Asset_Computation_RFI_Questions.pdf

INTERNAL REVENUE SERVICE (IRS)

REQUEST FOR INFORMATION (RFI)

RFI QUESTIONS

DIGITAL ASSET COMPUTATION SUPPORT SERVICES (IRS-DA_COMP_SVCS)

MARCH 3, 2026

INSTRUCTIONS

Vendors shall respond to the questions below. Responses should be concise, factual, and directly address the draft Performance Work Statement (PWS) for Digital Asset Computation Support Services.

To support market research (including identification of the prospective vendor pool, potential contract vehicles, and potential set-asides), vendors are encouraged to provide sufficient detail regarding corporate capabilities, relevant past performance, staffing approach, security posture, and indicative pricing information.

Do not include any taxpayer information, personally identifiable information (PII), or other sensitive data in your response.

1. CORPORATE CAPABILITIES AND RELEVANT EXPERIENCE

1.1 Provide a brief overview of your company’s core capabilities relevant to digital asset computation support for tax examination or similar financial/regulatory use cases.

1.2 Describe your experience performing digital asset transaction analysis and gain/loss computations. Include at least two examples of similar work performed within the last five years (Government or commercial). For each example, provide: customer, scope, transaction volume, data sources (exchange exports, APIs, on-chain), deliverables produced, and outcomes.

1.3 Describe your experience supporting matters that proceeded to administrative appeal and/or litigation, including preparation of defensible computation workpapers, expert reports, declarations, or testimony support (as applicable).

1.4 Identify any subcontractors or teaming partners you anticipate using for this requirement and the capabilities they would provide.

2. TECHNICAL APPROACH: DATA INGESTION AND STANDARDIZATION

2.1 Describe your end-to-end approach for ingesting and standardizing heterogeneous digital asset datasets (CSV/Excel, API-based data, blockchain explorer data, PDF statements, and other records).

2.2 Describe your approach to reconciling incomplete or inconsistent data (e.g., missing basis, missing acquisition records, gaps in exchange history, wallet-to-exchange transfers). How do you document exceptions and assumptions?

2.3 Describe your ability to support analysis across multiple platforms and wallets, including cross-platform transfers, peer-to-peer activity, and on-chain/off-chain tracing.

2.4 Describe your ability to ingest data from evolving or previously unsupported sources (e.g., new chains, tokens, protocols). Include any dependencies on third-party data access, API keys, licensing, or vendor relationships.

3. TECHNICAL APPROACH: VALUATION, BASIS, AND COMPUTATION OUTPUTS

3.1 Describe your valuation methodology for converting digital asset activity to U.S. dollars (USD). Address valuation sources, timestamp handling, and how you handle assets lacking reliable USD trading pairs.

3.2 Describe supported cost basis methods (e.g., FIFO, specific identification, HIFO/LIFO where applicable) and your process for documenting the selected method(s) and lot selection approach.

3.3 Describe how your computations trace acquisitions and dispositions back to ingested source records and how you generate a transfer analysis (including identification of potentially non-taxable transfers between accounts).

3.4 Describe how you generate workpaper outputs that support IRS reporting needs (e.g., Form 8949 detail) and any standardized templates you can support.

3.5 Describe your approach for DeFi and complex transaction types (e.g., swaps, liquidity pools, bridging, staking rewards, lending/borrowing, margin activity, NFTs, smart contract interactions). Identify any limitations and how you would communicate them.

4. REPRODUCIBILITY, DOCUMENTATION, AND QUALITY CONTROL

4.1 Describe how you ensure computational outputs are reproducible and defensible (e.g., documentation of data sources, transformations, reconciliation steps, assumptions, and manual adjustments).

4.2 Describe your internal quality control process for verifying completeness and accuracy prior to delivery to the Government, including any peer review, automated validation, and defect tracking.

4.3 Describe your approach to version control for datasets and reports, including how revised reports are produced and how changes are documented.

4.4 Provide any recommended quality metrics and/or acceptance criteria the Government should consider using in its QASP for this requirement.

5. SECURITY, COMPLIANCE, AND DATA HANDLING

5.1 Describe your approach to safeguarding IRS data consistent with Publication 1075 requirements (including access control, encryption at rest and in transit, audit logging, and incident response).

5.2 Describe the environment where data ingestion and computations would occur (cloud-hosted, on-premises, hybrid). If cloud-hosted, identify whether the solution is FedRAMP Authorized (and at what baseline).

5.3 Describe your approach to secure data transfer with Government counterparts (e.g., encrypted file transfer, secure portals).

5.4 Describe your data retention, archival, and secure destruction practices for case data and deliverables.

5.5 Describe any anticipated requirements for staff-like access, background investigations, and onboarding timelines for key personnel.

6. STAFFING AND SURGE CAPACITY

6.1 Provide a notional staffing model for supporting concurrent casework. Identify key roles (e.g., digital asset tax/accounting SME, data analyst, IT/security support) and expected labor categories.

6.2 Describe how you would scale staffing for high-complexity cases (e.g., 1,000,000+ transactions; 10+ platforms; DeFi activity).

6.3 Describe your approach to continuity of operations and minimizing turnover risk for key personnel assigned to the contract.

7. SCHEDULE, PERFORMANCE TIMELINES, AND CASE COMPLEXITY

7.1 Based on the draft PWS timelines (e.g., ingestion report and computation report sequencing), describe your ability to meet these timelines for low/medium/high complexity cases. Provide any recommended modifications or assumptions required to meet the timelines.

7.2 Describe your approach to estimating hours by case complexity and managing work within approved hours (including how you would surface schedule risk early).

7.3 Describe how you would manage ad hoc meetings, office hours, and technical briefings with IRS stakeholders while maintaining case throughput.

8. PRICING INPUTS FOR IGCE (BUDGETARY INFORMATION ONLY)

8.1 Provide budgetary pricing information to support IGCE development (not a proposal). Where possible, include fully burdened hourly rates by labor category or indicative pricing by case complexity tier.

8.2 Identify any non-labor cost drivers (e.g., licensing, data subscriptions, blockchain analytics tools, storage, travel for litigation support) and how you typically structure these costs.

8.3 Recommend a pricing and CLIN structure that best aligns with a work-order/case-based requirement (e.g., labor-hour, fixed-price per case tier, hybrid). Explain tradeoffs.

9. ACQUISITION STRATEGY INPUTS

9.1 Recommend appropriate NAICS code(s) and Product Service Code(s) (PSC) for this requirement and explain your rationale.

9.2 Identify existing Federal contract vehicles through which you could perform this work (e.g., GSA MAS, GWACs). Provide contract number(s) and labor categories relevant to this requirement.

9.3 Identify your business size and any socioeconomic status (e.g., small business, 8(a), SDVOSB, HUBZone, WOSB).

9.4 Provide any feedback on the draft PWS: ambiguities, risks, or recommendations to improve clarity, measurability, and performance management.