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

For years, US crypto holders kept one universal pool of cost basis and drew lots from it as if every wallet were a single account. On 1 January 2025 that approach became non-compliant. IRS Rev. Proc. 2024-28 ties basis to the specific wallet or account that holds the units, and it gives taxpayers a one-time allocation to carry their pre-2025 basis into that structure. This is the US-specific deep dive: the per-wallet rule itself, how the safe-harbor allocation works step by step, and the Form 1099-DA reporting timeline that makes getting the allocation right a near-term priority. For how the US rule compares with the methods other countries mandate, see the cost basis methods pillar.

The short version

• From 1 January 2025, US crypto cost basis is tracked per wallet and account; the universal or aggregate approach is no longer allowed.
• A disposal from a given wallet uses the basis of units held in that same wallet or account.
• A one-time safe harbor lets you allocate unused basis as of 1 January 2025 to your wallets, by specific-unit assignment or a reasonable global method.
• The permitted methods are FIFO (the default) or Specific Identification made at or before the sale with records, now applied per wallet (see tax-lot selection).
• Form 1099-DA brings broker reporting of gross proceeds for 2025 sales, with adjusted-basis reporting phasing in from 2026.
• Continuing to use universal basis after 2025 produces a non-compliant figure.

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, so 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 or account. You can no longer reach into a single universal ledger and select any unit you hold anywhere, which 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 the remaining unused basis as of 1 January 2025;
• to the wallets and 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 one. It has to be applied properly and consistently, and it is fact-specific: the choices you make have downstream consequences for every later disposal.

The methods, now wallet-bounded

HIFO and LIFO are not separate elections; they are achievable only through a 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 receives proceeds; basis reporting follows. That 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 the phased 1099-DA reporting will increasingly contradict. The compliant path is a safe-harbor allocation as of 1 January 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.

Choosing a tool for the transition

The per-wallet switch is a one-off migration as much as an ongoing calculation, so the tool you use has to handle both. Several, including CoinLedger and CoinTracker, advertise Rev. Proc. 2024-28 support, but the label alone is not enough. Before you commit a year of records to one, confirm it:

• produces a documented 1 January 2025 allocation you can defend, recording the method chosen and how unused basis was assigned to each wallet, rather than silently re-pooling everything;
• enforces the per-wallet boundary on every disposal and every specific identification afterwards, so a sale from one wallet can never borrow a lot from another;
• can reconcile its output against the Form 1099-DA proceeds your brokers report for 2025, ahead of the basis-reporting layer in 2026.

A tool that still computes basis from a universal pool after 2025 will hand you a clean number that is nonetheless non-compliant.

Step-by-step: performing the Rev. Proc. 2024-28 safe-harbor allocation

The transition from universal to per-wallet basis is a one-time allocation that must be performed correctly, because every future disposal's cost basis depends on it. The following sequence describes a defensible approach.

Step 1 — Establish the pre-2025 universal basis inventory

As of 31 December 2024 (the last day of the old universal-pool regime), compile the full list of:

• Every digital asset held, with units and cost basis per lot (acquisition date, per-unit cost, total cost);
• Every wallet and exchange account that held those assets, with the actual balance in each.

This is the foundation for the allocation. If lot records are incomplete (common for holders with years of history across many wallets), the allocation methodology must be documented — working from the best available data, consistently.

Step 2 — Choose the allocation method

Rev. Proc. 2024-28 permits either:

• Specific-unit allocation: assign particular lots to the wallet/account that actually held those units on 1 January 2025. This is the more precise approach and preserves lot-level holding-period data.
• Global allocation method: allocate remaining unused basis across wallets proportionally (e.g. by balance weight), where individual lot tracking is not feasible. The method must be reasonable and documented.

The choice is fact-specific. A taxpayer with good lot records and a small number of wallets generally benefits from specific-unit allocation; a taxpayer with large, commingled historical holdings may have to use a global approach.

Step 3 — Perform and document the allocation

For each wallet or exchange account as of 1 January 2025:

• Record the digital assets held, the units, and the allocated cost basis (from Step 2);
• Tie the allocated basis to the pre-2025 lot history — each dollar of allocated basis must be traceable to a lot that was purchased before 2025.
• Document the methodology, the decisions made (especially where records were incomplete), and the person who performed the allocation.

This documentation is the safe-harbor evidence. It should be retained alongside tax records for the applicable period.

Step 4 — Configure ongoing per-wallet tracking

From 1 January 2025 forward, every acquisition is recorded into the specific wallet/account where it lands. Every disposal is matched only against the lots held in that same wallet at the time of sale. A transfer from Wallet A to Wallet B carries cost basis with it (it is not a disposal), but the transferred basis is now tracked within Wallet B, not Wallet A.

If new wallets are created after 1 January 2025, they are tracked from their first acquisition — no allocation is needed for new wallets, only for the transition of pre-existing holdings.

Step 5 — Prepare for Form 1099-DA cross-checking

Starting with 2025 tax year sales, brokers report gross proceeds on Form 1099-DA. Basis reporting phases in from 2026. This means the IRS will have proceeds data for 2025 sales before it has the cost basis data — creating a window where per-wallet basis accuracy and the safe-harbor allocation are essential to avoid discrepancies when the basis layer arrives in 2026. Reconcile the safe-harbor allocation to the 1099-DA proceeds data before filing, not after.

Where Wag3s fits

Wag3s Folio performs the Rev. Proc. 2024-28 safe-harbor allocation as of 1 January 2025, records the method and the per-wallet assignment so the allocation is documented rather than implicit, then tracks basis per wallet and account with FIFO or documented Specific Identification from that point on. It reconciles toward the Form 1099-DA timeline, matching its figures against the proceeds brokers report for 2025 before basis reporting arrives in 2026. Because the allocation is fact-specific and consequential for years of future disposals, Folio is built to support a qualified US tax adviser's review of that allocation, not to replace it.

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, the one-time safe harbor to allocate unused basis (specific-unit or reasonable global allocation), and the FIFO or Specific Identification methods. Universal/aggregate tracking is no longer permitted.
• IRS — About Form 1099-DA, Digital Asset Proceeds From Broker Transactions: brokers report gross proceeds for sales on or after 1 January 2025, with basis reporting on certain transactions from 1 January 2026.
• IRS — Digital assets hub and Frequently asked questions on digital asset transactions for the broader US digital-asset reporting framework.