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Crypto Basis Per Wallet: Rev. Proc. 2024-28 Explained

Short answer: Revenue Procedure 2024-28 says final regulations (T.D. 10000) apply specific identification and FIFO to units held within a single wallet or account for acquisitions and dispositions on or after January 1, 2025. The revenue procedure gives a safe harbor that lets you make any reasonable allocation of your unused basis to the wallets or accounts that hold the same number of remaining units as of January 1, 2025, if you meet its requirements. This is why records for each wallet matter now that brokers report on Form 1099-DA.

Background (from the rev. proc.)

• The IRS FAQs (before 2025) allowed specific identification by unique identifier or by records for units held in a single account, wallet or address, and otherwise FIFO. Many taxpayers read them as allowing a universal or multi-wallet approach.
• The 2024 final regulations apply the rules on an account-by-account basis. The rev. proc. helps people transition so basis records do not diverge from brokers' reporting.

Who can use the safe harbor

• You hold remaining units and unused basis as of January 1, 2025.
• Each remaining unit and the original unit of basis are capital assets and the same type of digital asset (for example bitcoin for bitcoin).
• You can show total remaining units in each wallet or account, and the units and original cost and acquisition date of unused basis.
• The allocation is irrevocable for section 1012 purposes.
• It does not apply to assets acquired or transferred to you on or after January 1, 2025, or to basis under court, Appeals or IRS examination first contacted before that date.

Two ways to allocate

• Specific unit allocation: you assign specifically identified units of unused basis to the pool of units in each wallet or account (or to the specific units).
• Global allocation: you describe a rule, in your books before January 1, 2025, that orders the units of unused basis and allocates them to wallets in a prescribed way, without later discretion.

Deadlines (specific unit allocation)

Complete it before the earlier of the first sale, disposition or transfer of that type of asset on or after January 1, 2025, or the due date (including extensions) of your 2025 return. Until then you must keep units acquired on or after 2025 separately accounted for. For a global allocation, the method had to be described in your books and records before January 1, 2025, and it must be completed before the later of those two dates (section 5.02(5)); a global method can no longer be adopted now.

Limits

The safe harbor only covers which wallet or account holds your unused basis; it does not prove the amount of basis, which you must substantiate separately (section 5.04), and you cannot reallocate basis you already used (section 5.02(7)).

Reporting rules (T.D. 10000)

Treasury Decision 10000 (§1.1012-1(j)(6)) applies the wallet-by-wallet rules to all acquisitions and dispositions of digital assets on or after January 1, 2025. Brokers report gross proceeds on Form 1099-DA for transactions from 2025, and basis only for assets acquired in the customer's account at the same broker on or after January 1, 2026.

Made-up illustration

You held 2 coins in wallet A and 2 in wallet B on January 1, 2025, with unused basis of $10, $20, $30 and $40 across 4 coins. The safe harbor lets you allocate those four basis units reasonably across the wallets, as long as you document it by the deadline and keep it consistent.

Related

Which units did you sell? Lot ID · After moving crypto between exchanges · Covered vs noncovered · Wrong basis on a 1099-DA

FAQ

Is the deadline over? For a specific unit allocation, section 5.02(4) required you to complete it before the earlier of your first sale, disposition or transfer of that type of digital asset on or after January 1, 2025, or the due date (including extensions) of your 2025 return. For most people with a six-month extension that date (normally October 15, 2026) has now passed; we did not confirm that date on irs.gov. Check your records and speak to a tax professional if you have not documented an allocation.

Does this change the 2026 rules? The regulations apply to 2025 onward; this page does not cover later guidance.

What we could not verify

• Notice 2025-7 (temporary relief on identification for assets held with a broker) and IRS FAQ 94 were not read in detail.
• Whether the extended 2025 return due date (normally October 15, 2026) has passed for you; not confirmed on irs.gov.
• The T.D. 10000 text was reported by our checker, not read by us.
• How a specific broker applies the rules.

Sources (official)

• IRS, Rev. Proc. 2024-28: Guidance for taxpayers to allocate basis in digital assets to wallets or accounts as of January 1, 2025 — https://www.irs.gov/pub/irs-drop/rp-24-28.pdf (read through section 5.02 on 17 October 2026)
• IRS, T.D. 10000 (I.R.B. 2024-31; §1.1012-1(j)) — https://www.irs.gov/irb/2024-31_IRB

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Not tax advice. Examples use made-up figures. Nothing here has been reviewed by a tax professional. We may earn commissions from affiliate links where marked; see the disclosure.