IRS-DA_COMP_SVCS

Questions & Answers / Clarifications

This document provides responses to vendor questions regarding the Performance Work Statement (PWS) for a digital asset computation support program.

• Minimum Support Volume: The IRS estimates approximately 210 low-complexity, 65 medium-complexity, and 25 high-complexity cases in the first year. These are planning estimates and not minimum guaranteed volumes. Internal IRS resources may handle some low and medium complexity cases.
• Platforms/Datasets Definition (Custodial Data): Records from a single custodial broker are generally considered one dataset, even if multiple data files (e.g., trading activity, deposits) are provided. Separate datasets may be created if business or legal reasons require separate computations (e.g., spouses filing separately).
• Platforms/Datasets Definition (Non-Custodial/Digital Asset Data): Each self-custodial wallet is generally considered a single dataset. If a wallet uses a unified private key structure, it's treated as one dataset, regardless of the number of individual addresses, unless separate technical or analytical treatment is required.
• Staffing: The IRS does not maintain a fixed staffing model; contractor staffing levels are determined by the contractor based on requirements and workload.
• Labor Categories: Roles include Virtual Currency SMEs, Project Managers, Data Ingest Analysts, and other technical/tax specialists.
• Current Contract Pricing: The incumbent contract is Firm-Fixed-Price. Future solicitations may shift to labor-hour or a hybrid model.
• Platform Licensing Costs: Contractors are expected to include platform licensing costs within their pricing structure, as they must provide their own digital asset computation software.
• Cases Processed: Approximately 200 cases have been processed under the current contract.
• Transaction Volume: Cases commonly involve hundreds of thousands of transactions, but can range from tens of thousands to over ten million.
• Case Assignment: Cases are assigned using a work-order model.
• High Complexity Cases: Cases exceeding one million transactions are classified as high complexity. Approximately 25 out of an estimated 300 cases may fall into this category.
• Litigation Support Pricing: Offerors should propose reasonable assumptions and methodologies for estimating litigation support costs, accounting for variability in timelines and scope.
• FedRAMP: Any proposed cloud-based solution must possess FedRAMP authorization at the time of award. Offerors must describe how their solution meets federal security standards, including FedRAMP.

These clarifications provide essential details for bidders to understand case complexity, data handling, staffing expectations, and security requirements, which will inform proposal development and pricing.

Questions & Answers / Clarifications

This document contains questions from vendors and instructions for responding to the IRS Request for Information (RFI) regarding Digital Asset Computation Support Services. The responses are intended to aid the IRS in market research, including identifying potential vendors, contract vehicles, and set-asides.

Vendors are instructed to provide concise, factual responses directly addressing the draft Performance Work Statement (PWS). Responses should detail:

• Corporate Capabilities and Relevant Experience: Overview of capabilities, experience with digital asset transaction analysis and gain/loss computations (with examples), experience with administrative appeal/litigation support, and identification of subcontractors.
• Technical Approach: Methods for data ingestion and standardization, reconciliation of incomplete data, analysis across platforms/wallets, and handling evolving data sources.
• Valuation, Basis, and Computation Outputs: Valuation methodology, cost basis methods (FIFO, specific identification, HIFO/LIFO), tracing computations, workpaper generation for IRS reporting (e.g., Form 8949), and handling complex transaction types (DeFi, NFTs, etc.).
• Reproducibility, Documentation, and Quality Control: Ensuring reproducible and defensible outputs, internal quality control processes, and version control for datasets and reports.
• Security, Compliance, and Data Handling: Safeguarding IRS data per Publication 1075, data ingestion/computation environment (cloud, on-premises, hybrid), secure data transfer, and data retention/destruction.
• Staffing and Surge Capacity: Notional staffing models, scaling for high-complexity cases, and continuity of operations.
• Schedule, Performance Timelines, and Case Complexity: Meeting PWS timelines for various case complexities, estimating hours, and managing stakeholder interactions.
• Pricing Inputs (Budgetary Information Only): Indicative pricing, non-labor cost drivers, and recommended pricing/CLIN structures.
• Acquisition Strategy Inputs: Recommended NAICS/PSC codes, existing contract vehicles, business size/socioeconomic status, and feedback on the draft PWS.

Vendors are explicitly instructed not to include taxpayer information, PII, or other sensitive data in their responses.

This RFI is for market research purposes and does not constitute a solicitation. Responses will inform the government's acquisition strategy and the development of the final PWS and solicitation. Vendors are encouraged to provide detailed feedback on the draft PWS to improve clarity and measurability.

Statement of Work (SOW) / Performance Work Statement (PWS)

The Internal Revenue Service (IRS) seeks Digital Asset Computation and Data Analysis services to support examination activities involving digital assets. The goal is to assist the IRS in calculating taxpayers' taxable income and gains and/or deductible losses resulting from digital assets transactions.

The contractor shall provide Digital Asset Computation Support, including specific case support as detailed in various tasks. This involves providing personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, and other non-personal services, except for IRS-furnished property and services. The work includes digital asset computation and report generation.

• Base Period: August 13, 2026 to August 12, 2027

• Four 12-month option periods.

• Place of Performance is not specified, but services are expected to be performed under contract.

• Digital Asset Computation and Report Generation: This is the primary service area.

• Case Ingestion Conference: Participate in a conference to establish case complexity, timeframes, scope, and valuation sources.

• Case Computation Plan: Provide a written plan within 3 workdays after the ingestion conference.

• Digital Asset Computation Report: Generate a report detailing gain/loss computations, transfer analysis, and methodology.

• Data Ingestion: Support for ingesting data from various sources, including on-chain, off-chain, APIs, and exchange data.

• Litigation Support: Provide services for pending civil and criminal litigation, including preparing computations, appearing as a witness, and explaining methodologies.

• Non-Personal Services: The government will not supervise contractor employees or assign work schedules.

• Key Personnel: Specific roles such as Lead Digital Asset Tax and Accounting Subject Matter Expert, Lead Data Analyst, IT Senior Consultant, IT Subject Matter Expert, and Software Support Lead are required.

• Security: Contractor personnel will require identification badges and may need staff-like access, involving background investigations and training.

• Quality Control: Contractor must develop and implement a Quality Control Plan (QCP).

• FedRAMP Standards: Contractor software capability must meet FedRAMP standards.

Request for Information (RFI)

This RFI is issued by the Internal Revenue Service (IRS) for market research and planning purposes to identify potential sources for Digital Asset Computation Support Services. The IRS is increasingly involved in examining digital assets and requires specialized capabilities for data ingestion, computation, and analysis. This RFI is not a solicitation and does not commit the government to a contract. No costs incurred in responding will be reimbursed.

• Work-order driven case support, including ingestion conferences and computation planning.

• Ingesting and normalizing datasets from various sources (exchanges, APIs, blockchains).

• Reconciling and valuing digital assets in USD.

• Producing computation deliverables such as ingestion reports, gain/loss calculations, and IRS workpaper templates.

• Providing Quality Control (QC) and documentation for replication and verification.

• Optional litigation support services.

• Safeguarding IRS information per Publication 1075.

• Potential background investigations for personnel.

• Secure tools and infrastructure for large-scale analysis with access controls and audit logging.

• Responses are due via email by 11:59 PM Eastern on March 20, 2026, to RYAN.M.DOLAN@IRS.GOV.

• Submissions are limited to a maximum of 16 pages (15 pages plus a cover page).

• Responses should include company information, capabilities relevant to the draft PWS, employee numbers, business type, NAICS/PSC codes, and relevant contract vehicles.

• The government will weigh capability, quality, feasibility, experience, reproducibility, QC, ability to support sensitive matters, staffing/surge strategy, security controls, and overall risk.

• Responses will be used to identify potential sources, vehicles, and set-asides for specific small business classifications.

• There is no funding set aside at this time.

• Questions regarding the RFI are due by 11:59 PM Eastern on March 9, 2026, via email to RYAN.M.DOLAN@IRS.GOV.

• Answers will be posted on SAM.gov.

• The attached draft Performance Work Statement (PWS) is in early stages and may be refined.

• Responses are not offers and will not be considered as proposals for a future solicitation.