US Crypto Per-Wallet Cost Basis: Rev. Proc. 2024-28

For years US crypto holders pooled all their basis into one universal ledger and picked lots from it. That ended on 1 January 2025. IRS Rev. Proc. 2024-28 makes cost basis per-wallet, with a one-time allocation to get there. This guide is the rule, the safe harbor, and the 1099-DA timeline.

TL;DR

• From 1 Jan 2025, US crypto cost basis is per wallet/account — universal/aggregate is no longer allowed.
• Selling from a wallet uses the basis of units in that same wallet/account.
• One-time safe harbor: allocate unused basis as of 1 Jan 2025 to wallets (specific-unit or reasonable global allocation).
• Methods: FIFO (default) or Specific Identification (at/before sale, records) — per wallet (see tax-lot selection).
• Form 1099-DA: gross proceeds for 2025 sales; basis reporting from 2026.
• Continuing universal basis after 2025 is non-compliant.

The rule: per wallet, not universal

Before 2025, many US taxpayers tracked crypto basis on a universal (aggregate) basis — one pool across all wallets and exchanges. Rev. Proc. 2024-28 ends that. From 1 January 2025, basis is tracked per wallet and per account: when you dispose of units from a specific wallet or exchange account, you must use the cost basis of units held in that same wallet/account. You can no longer reach into a single universal ledger and select any unit you hold anywhere (this is also why specific identification is now wallet-bounded).

The safe harbor: getting from universal to per-wallet

You do not lose pre-2025 basis in the transition — Rev. Proc. 2024-28 provides a one-time safe harbor:

• allocate remaining unused basis as of 1 January 2025;
• to the wallets/accounts that held digital assets;
• using either a specific-unit allocation or a reasonable global allocation method.

This allocation is the bridge between the old universal world and the new per-wallet world. It must be applied properly and consistently, and it is fact-specific — the allocation choices have downstream consequences for every later disposal.

The methods, now wallet-bounded

HIFO/LIFO are not separate elections — only achievable via valid Specific Identification (see FIFO vs LIFO vs HIFO and tax-lot selection). The per-wallet boundary now constrains every identification.

The Form 1099-DA timeline

For 2025 the IRS gets proceeds; basis reporting follows. The gap makes accurate per-wallet basis and a sound safe-harbor allocation important before the basis-reporting layer arrives and starts cross-checking your numbers — the same "reconcile before the data lands" logic as DAC8 in the EU.

The non-compliance trap

Continuing to compute basis from a universal pool after 1 January 2025 produces a figure that does not match the required method and that phased 1099-DA reporting will increasingly contradict. The compliant path is: safe-harbor allocation as of 1 Jan 2025, then per-wallet tracking thereafter (see cost-basis methods).

Practical guidance

1. Stop universal tracking for US holdings from 1 January 2025.
2. Perform the safe-harbor allocation of pre-2025 unused basis to wallets/accounts.
3. Track per wallet/account thereafter — disposals use that wallet's basis.
4. Use FIFO or documented Specific ID, bounded to the wallet.
5. Prepare for 1099-DA — proceeds for 2025, basis reporting from 2026; reconcile early.
6. Document the allocation method — it is fact-specific and drives future gains.

How vendor tools handle the per-wallet rule

CoinLedger and CoinTracker implement per-wallet tracking and the Rev. Proc. 2024-28 safe-harbor allocation. Confirm the tool performs a defensible 1 Jan 2025 allocation, enforces the per-wallet boundary on every disposal and specific identification, and reconciles toward Form 1099-DA — a tool still computing universal basis after 2025 produces a non-compliant figure.

How Wag3s helps

Wag3s Folio performs the Rev. Proc. 2024-28 safe-harbor allocation as of 1 January 2025, tracks cost basis per wallet/account with FIFO or documented Specific Identification thereafter, and reconciles toward the Form 1099-DA proceeds-then-basis timeline. See the Folio product page.

Further reading

• Crypto Cost Basis Methods 2026
• Crypto Tax-Lot Selection
• FIFO vs LIFO vs HIFO for Crypto
• Realized vs Unrealized Gains in Crypto
• Crypto Portfolio PnL Calculation
• DAC8 Impact on Individuals

Sources

• IRS — Rev. Proc. 2024-28: per-wallet/account cost basis from 1 January 2025; one-time safe harbor to allocate unused basis (specific-unit or global allocation); FIFO or Specific Identification
• Form 1099-DA — broker gross-proceeds reporting for 2025 sales; adjusted-basis reporting phasing in from 2026
• Universal/aggregate cost-basis tracking no longer permitted after the per-wallet rule took effect