REVISION REQUIRED:

1. REMOVE or REVISE the FAQ answer about the de minimis exception. Replace with: 'The IRS has not issued specific guidance establishing or eliminating a de minimis threshold for crypto funding rate settlements. Current guidance treats each event as a reportable transaction. Every event is reportable unless future guidance changes this treatment.'

2. CLARIFY the NIIT statement. Revise the paragraph to: 'A $1M notional position in a crypto perp tracking the S&P 500 generates 1,095 reportable transactions annually, each subject to short-term capital gains rates up to 37% (for top-bracket taxpayers). Additionally, net investment income tax of 3.8% may apply to taxpayers with modified adjusted gross income exceeding $200,000 (single) or $250,000 (married filing jointly).'

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These are the only two flagged issues requiring revision. All other content passed review.