Rev. Proc. 2024-28 — Universal vs. wallet-by-wallet basis tracking. Get your safe harbor election right.
The January 1, 2025 transition deadline has passed. If you held digital assets on that date and have not made the wallet-by-wallet election, your basis tracking may not align with what brokers are now required to report. We handle the election, the allocation, and the documentation — so your 2025 and 2026 returns are clean from the start.
Schedule a 30-minute intake →The end of universal-method accounting for crypto.
Rev. Proc. 2024-28 provides the official IRS guidance for transitioning from global (universal) digital asset basis tracking to per-account, per-wallet basis tracking. It establishes a safe harbor that, if followed correctly, protects the transition from later IRS challenge.
One pool across all wallets
Under the universal method, all units of a given asset (say, all your ETH) were tracked in one global cost basis pool, regardless of which wallet or exchange held them. Specific identification was applied across wallets. This method is no longer compatible with IRC §6045 broker reporting, which tracks basis per-account.
Separate basis pool per wallet
Under the wallet-by-wallet method, each wallet and exchange account maintains its own basis pool. Specific identification applies within each account. This aligns with how IRC §6045 brokers track and report basis — meaning your records and your 1099-DA will agree, or can be reconciled cleanly.
What happened on January 1, 2025 — and why it matters.
January 1, 2025 was the transition date established by Rev. Proc. 2024-28. On that date, taxpayers who had been using the universal method were required to allocate their existing basis lots to specific wallets and exchange accounts. The safe harbor provides a methodology for doing this allocation in a way the IRS will respect.
Taxpayers who did not make the election or did not document the allocation face a significant risk: when their broker issues a 1099-DA in early 2026 showing basis for 2025 transactions, the broker’s per-account records may not match the taxpayer’s universal-method records. The IRS will get the broker’s version. Without a documented election and allocation, the taxpayer has no clean basis to dispute it.
If the transition date has already passed and you have not yet made the election, we can still prepare the documentation and include the election statement with your 2025 return. The window for doing this correctly is now — before the 2025 return is filed.
Universal vs. wallet-by-wallet — when each makes sense.
Simpler portfolio, one or two accounts
If you hold assets primarily on one or two exchanges and rarely move between wallets, the universal method may still be permissible for pre-2025 activity under certain conditions. However, you must still reconcile against broker 1099-DA reporting going forward, and the universal method creates increasing complexity as broker basis-reporting expands in 2026.
Multi-wallet, DeFi, or high-volume activity
If you hold assets across multiple wallets, use DeFi protocols, or have significant transaction volume, wallet-by-wallet tracking is the only method that will align with broker 1099-DA reporting and survive an audit. It is also the method that enables specific identification at the lot level within each wallet — which is the most tax-efficient approach for most active holders.
Four steps from election to clean 2025 books.
Inventory All Wallets & Accounts
We identify every wallet address, exchange account, and custodial account that held digital assets as of the transition date. Nothing is missed.
Rebuild Transition-Date Positions
We reconstruct your holdings as of January 1, 2025 from on-chain data and exchange records. This is the snapshot the election is built on.
Allocate Basis Lots
Using the Rev. Proc. 2024-28 safe-harbor methodology, we allocate your existing basis lots to each wallet and account. The allocation is documented in a format the IRS can audit.
File the Election Statement
The written election statement is prepared and attached to your 2025 federal return. Going forward, your books run on wallet-by-wallet basis — clean, documented, and aligned with broker reporting.
Need help with the Rev. Proc. 2024-28 election?
The window to make this election correctly is before your 2025 return is filed. Schedule an intake now and we’ll handle the full allocation and documentation.
Schedule a 30-minute intake →