United States
Internal Revenue Service (IRS)
Rules Implemented
Account-by-Account Basis (T.D. 10000)
Starting January 1, 2025, IRS Treasury Decision 10000 (89 FR 56480) requires cost basis tracking per wallet and per account under §1.1012-1(j). PrivateACB fully supports this with transfer lot movement, original account IDs, and Rev. Proc. 2024-28 safe harbor compliance.
1099-DA Box Categorization
PrivateACB categorizes Form 8949 transactions into the correct boxes based on whether your exchange issued a 1099-DA: Boxes G/H/I and J/K/L (basis reported, 2025+) or Boxes C and F (basis not reported, 2024 and earlier).
Wash Sale Rule (Optional)
Losses disallowed if substantially identical property acquired within 30 days before or after sale (IRC §1091). Denied losses are added to the replacement lot's cost basis. Optional — regulatory uncertainty for crypto. Disabled by default.
Short-Term vs Long-Term
Assets held less than one year are short-term gains (ordinary income rates). One year or more qualifies for preferential long-term capital gains rates. PrivateACB classifies every disposal automatically based on lot acquisition dates.
Reports Generated
- Form 8949 (Sales and Dispositions)
- Schedule D (Capital Gains Summary)
- Tax Lot Inventory (with account tracking)
- Wash Sale Report
- Income Report
- Tax Audit Report (with T.D. 10000 citations)
Lot Tracking Methods
Unlike Canada’s pooled ACB, the US tracks individual tax lots. Each acquisition is a separate lot with its own cost basis, acquisition date, and holding period.
FIFO (First In, First Out): Oldest lots are sold first. Default IRS method.
LIFO (Last In, First Out): Newest lots are sold first. May minimize short-term gains.
HIFO (Highest In, First Out): Highest cost lots are sold first. Minimizes realized gains.
Example (FIFO):
| Date | Action | Quantity | Price | Lot |
|---|---|---|---|---|
| Jan 15 | Buy 1.0 BTC | 1.0 | $50,000 | Lot 1 |
| Mar 10 | Buy 0.5 BTC | 0.5 | $60,000 | Lot 2 |
| Jun 20 | Sell 0.8 BTC | -0.8 | $65,000 | Lot 1 (FIFO) |
Gain: (0.8 × $65,000) - (0.8 × $50,000) = $12,000 (long-term if held > 1 year)
Account-by-Account Basis (T.D. 10000)
Starting January 1, 2025, IRS Treasury Decision 10000 requires that cost basis be tracked per wallet and per account — the universal pooling method is no longer permitted. When you sell crypto on one exchange, only lots held on that same exchange can be used for cost basis.
What PrivateACB does:
- Tracks lots by account automatically (derived from your import data)
- Applies FIFO within each account for transfers, per §1.1012-1(j)(1)
- Splits partial lots when transfers move assets between accounts
- Maintains an immutable original account ID for audit trail
- Supports the Rev. Proc. 2024-28 one-time safe harbor transition from universal to per-account tracking
Why this matters: Your 1099-DA may show $0 cost basis for assets transferred between wallets or acquired before 2025. PrivateACB calculates your actual cost basis and generates the documentation to support it.
Wash Sale Detection
If you sell at a loss and buy back within 30 days, the loss is disallowed and added to the cost basis of the replacement lot. PrivateACB flags these automatically — the Wash Sale Report shows every disallowed loss with the matching reacquisition.
This is optional. The IRS has not definitively ruled that wash sale rules apply to cryptocurrency. PrivateACB lets you toggle it on or off in Settings.
1099-DA and Form 8949
Starting in 2025, exchanges must file Form 1099-DA reporting gross proceeds to the IRS. Starting in 2026, they must also report cost basis. PrivateACB categorizes your Form 8949 transactions into the correct boxes based on whether each exchange issued you a 1099-DA:
| Tax Year | With 1099-DA | Without 1099-DA |
|---|---|---|
| 2024 and earlier | N/A | Box C (ST) / Box F (LT) |
| 2025 and later | Box G/H/I (ST) / Box J/K/L (LT) | Box C (ST) / Box F (LT) |
You configure which exchanges issued a 1099-DA in the Settings tab.
Regulatory References
- T.D. 10000 (89 FR 56480, July 9, 2024) — Per-account cost basis for digital assets under §1.1012-1(j)
- Rev. Proc. 2024-28 — One-time safe harbor for transitioning from universal to per-account tracking (irrevocable under §1012)
- Notice 2025-7 — Transitional relief for 2025 digital asset reporting
- IRC §1091 — Wash sale rule (loss from wash sales of stock or securities)
- IRC §1222 — Short-term and long-term capital gain definitions
- Form 8949 Instructions — Sales and Other Dispositions of Capital Assets
- Schedule D Instructions — Capital Gains and Losses