New 2025 US Tax Regulations - Universal to Per-Wallet Cost Basis Transition

Describe the problem:
In the US, the IRS recently released the requirements for the transition to per-wallet tracking in order to implement the form 1099-DA with crypto brokers for better transparency starting in 2025. In doing so, all of those people who have been using universal tracking are in a real tough spot here.

https://www.irs.gov/pub/irs-drop/rp-24-28.pdf

Unless if I am mistaken, simply switching to per-wallet tracking would change all of your prior year data, and likely require filing amended returns for everything, which is not a good option whatsoever, while not following the same FIFO per-wallet strategy as these brokers will likely lead to mass tax audits on people. Also not a good scenario. This is a big deal, so I am reaching out for guidance and support in a path moving forward for a date that is rapidly approaching with little to no time to spare, and I wanted to get this discussion started right away.

I struggle with grasping all technical lingo in the document, such as unused cost-basis, to be able to propose potential solutions to the matter.

Which exchange/wallet is this regarding?
All

How did you import data into this wallet?
Various

What have you tried to fix this so far?
To my knowledge, there is no quick fix.

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Hi @sltmunky69

Thank you for the information.

We will continue to monitor changes in U.S. tax regulations and implement necessary updates as soon as possible. In the meantime, if you have any feedback or suggestions for features you’d like to see in Koinly, feel free to share them on our feedback portal.

For example, other users have already requested a feature to lock the cost tracking method, allowing a switch from Universal to Wallet-based without impacting previous years:

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This feature definitely be needed for 2025

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Would the highlighted settings here be sufficient in complying with the new regulations when it comes to the cost basis tracking, or am I missing something else?

I had this in my settings as soon as I started in Koinly. I wanted to know if there is anything I should do differently in light of the new regulation.

Hi @Panda_Gaming

Your settings seem to be for Canada while this discussion is for the changes in the US tax law.

Hi @Rigsss

Our developers are working on this at the moment.

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Hi @Panda_Gaming @peacew6 @sltmunky69 @Rigsss

Thanks for your patience.

We have just released an article on this case. Please check it out:

Migrating to wallet-based cost tracking under new IRS guidance (USA only)

@Aria_Koinly After reading the article, I still have a few questions. Can you please confirm the following? Optimizing the wallets (addresses) is only beneficial if my accounting method is FIFO. If I elect HIFO, the coins with the highest cost basis will get sold first so optimizing wallets doesn’t produce any tax advantage. With this new Proc 2024-28, the IRS does allow me to use HIFO as my accounting method. Am I correct about these?

Also, if exchanges will be sending their wallet based 1099 to the IRS how will they know the cost basis for the tokens being sold? Will their wallet override the wallet the tokens were in before sending them to be sold.

There’s no way I’m keeping my coins in a CEX wallet not after what happened with FTX/BlockFi/Celsius.

I have no doubts about Koinly tracking everything correctly but I’ve no idea if/how that wallet info will sync with the CEXs and what they report to the IRS and whether the two will be aligned.

Messy.

CEXs will have require you to provide the cost basis of the coin you’re transferring to them.

1 Like

OK - that’s fine - would be great if there could be integration at some point - but having a service like Koinly certainly makes this relatively simple.

Thanks for raising this question! Feeling relied knowing that Koinly will help with the migration.

My only question is - the CEXs won’t know all these allocations/cost basis prior to 2025 so their 1099DA will most likely be wrong. Do we simply ignore that and use Koinly file when it comes to 2025 filling or how to proceed there? Thanks!

Hi @R_C1

Regarding 1099 form, check out our blog post below:

https://koinly.io/blog/crypto-1099-k-1099-b-1099-misc/