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Coinbase Q4 $667M Loss: What It Means for Your Crypto Taxes and 1099-DA

✍️ Written by Davit Cho

Crypto Tax Specialist & CEO at JejuPanaTek

13+ Years Experience | Patent #10-1998821 | IRS Compliance Expert

davitchh@proton.me

Coinbase Q4 $667M Loss: What It Means for Your Crypto Taxes and 1099-DA

Coinbase Q4 667M loss crypto tax impact 2026 with cracking logo and falling chart

On February 12, 2026, Coinbase (COIN) reported a $667 million net loss for Q4 2025 — ending an 8-quarter profit streak. Revenue dropped 22% year-over-year to $1.78 billion. Trading revenue crashed 37% YoY to $983 million. COIN stock closed at $141, down 68% from its all-time high of $444.

But here's what most investors are missing: this earnings report has direct tax implications for every Coinbase user filing in 2026. Your 1099-DA is arriving (deadline: Feb 17), cost basis rules just changed, and the numbers on that form may be dangerously incomplete.

⚠️ 1099-DA DEADLINE: FEBRUARY 17, 2026
Coinbase must deliver your Form 1099-DA by Feb 17, 2026. For 2025 transactions, this form reports only gross proceeds — NOT cost basis. If you file using only 1099-DA data, the IRS will treat your entire sale amount as 100% profit. IRS Source →

⚡ Quick Facts — Coinbase Q4 2025

  • Q4 Net Loss: $667M (vs $1.29B profit in Q4 2024)
  • Q4 Revenue: $1.78B (‑22% YoY, ‑5% QoQ)
  • Q4 Trading Revenue: $983M (‑37% YoY)
  • COIN Stock: $141.09 close (‑68% from $444 ATH)
  • Cash Reserves: $11.3B
  • Share Buyback: $1.7B (Q4 + Feb 2026)
  • Coinbase One Subscribers: ~1 million
  • 1099-DA: First year issued; gross proceeds only for 2025
  • Cost Basis Reporting: Mandatory starting Jan 1, 2026 transactions

1. Coinbase Q4 by the Numbers

MetricQ4 2025Change
Total Revenue$1.78B‑22% YoY
Transaction Revenue$983M‑37% YoY
Consumer Transaction Revenue$734M‑13% QoQ
Institutional Transaction Revenue$185M+37% QoQ
Subscription & Services$727M‑3% QoQ
Stablecoin Revenue$364M+3% QoQ
Net Income (Loss)($667M)vs +$1.29B Q4'24
Adjusted EBITDA$566M‑56% YoY
Adjusted Net Income$178MOperationally profitable
COIN Stock Close$141.09‑68% from ATH ($444)
After-Hours$142.31‑7.9% on day
Cash & Equivalents$11.3B‑$0.7B QoQ
Share Buyback (Q4 + Feb '26)$1.7B8.2M shares total
Full Year Revenue$7.2B+9% YoY
Full Year Trading Volume$5.2T+156% YoY
Coinbase One Subscribers~1M3x in 3 years
Employees4,951+31% YoY

Source: Coinbase Shareholder Letter, Feb 12, 2026

πŸ“Œ Related Guide

Understand the new per-wallet cost basis rule that impacts every Coinbase user

Per-Wallet Cost Basis Migration Guide →

2. Why the $667M Loss Isn't What You Think

The headline is alarming — but the breakdown tells a completely different story:

ComponentAmountType
Crypto asset portfolio loss$718MLargely UNREALIZED
Strategic investment loss (incl. CRCL)$395MPaper loss
Adjusted Net Income (operations)+$178MProfitable
Adjusted EBITDA+$566MCash-generating

Translation: Coinbase's core business still made money. The $667M loss was driven almost entirely by unrealized drops in their own crypto holdings (mainly BTC and ETH) — not by operational failure. They hold $11.3B in cash, repurchased $1.7B of their own stock, and still generated positive Adjusted EBITDA.

πŸ’‘ Why this matters for YOUR taxes: If Coinbase — a public company with hundreds of accountants — got hit by $718M in unrealized crypto losses, the same market decline is sitting in your Coinbase account right now. The question is whether you're reporting it correctly. Unrealized losses don't help you at tax time — but realized losses through tax-loss harvesting can save you thousands.

πŸ“‰ Turn Losses Into Savings

BTC is down 48% from ATH. Learn how to harvest those losses legally.

Tax-Loss Harvesting Mega Guide →

3. Your 1099-DA: What Coinbase Reports vs. What It Doesn't

Coinbase 1099-DA missing cost basis trap showing form with unknown basis highlighted

This is the first year Coinbase is required to issue Form 1099-DA. Here's what's on it — and what's critically missing:

Field2025 Transactions (This Filing)2026+ Transactions (Next Year)
Date of sale✅ Reported✅ Reported
Gross proceeds✅ Reported✅ Reported
Cost basis❌ NOT reported✅ Covered assets only
Gain/loss calculation❌ NOT reported❌ Partial
Transferred-in assets basis❌ Shows $0❌ Still shows $0
DeFi / DEX transactions❌ Not included❌ Not included
Crypto-to-crypto trades✅ Reported✅ Reported
🚨 The Critical Danger: The IRS gets a copy of your 1099-DA showing your sales proceeds. Without cost basis, the IRS computer matches your sale at $0 cost = 100% taxable profit. You sold 1 BTC for $66,000? The IRS sees $66,000 in taxable gains — unless you report the correct cost basis yourself on Form 8949.

What Coinbase Cannot Track

Even when cost basis reporting becomes mandatory for 2026 transactions, Coinbase still cannot report basis for:

→ Crypto transferred IN from another exchange (MetaMask, Kraken, Ledger, etc.)
→ Crypto purchased before your Coinbase account was created
→ Crypto acquired through mining, airdrops, staking rewards, or hard forks
→ Crypto received as payment or gifts
→ Any DeFi/DEX activity (Uniswap, Aave, etc.)

For all of these, you are responsible for calculating and reporting cost basis on Form 8949. Coinbase's 1099-DA will show these as $0 basis — which means 100% taxable if you don't correct it.

Sources: Coinbase Help — 1099-DA · IRS — Understanding Form 1099-DA · Awaken Tax — Coinbase 1099-DA Limitations

4. The Missing Cost Basis Trap (With Dollar Examples)

Let's say you sold 1 BTC on Coinbase in 2025 for $66,000. Here's what happens depending on how cost basis is reported:

ScenarioCost BasisTaxable ResultTax @ 24%
1099-DA only (no basis reported) $0 +$66,000 gain $15,840
FIFO default (bought at $35K in 2021) $35,000 +$31,000 gain $7,440
Average cost (if it were allowed) $66,000 $0 $0
Specific ID (bought at $97K in 2024) $97,000 ‑$31,000 loss $0 (+ deduction)

$15,840 vs. $0

Same 1 BTC sale. Same Coinbase account. The only difference: whether you report cost basis correctly.

✅ Key Takeaway: Never file your taxes using only the 1099-DA numbers. Always calculate your actual cost basis using purchase records or crypto tax software. Use Specific Identification to select the highest-cost lots first (HIFO strategy) — this minimizes gains or maximizes deductible losses.

5. Per-Wallet Rules: How Coinbase Handles the New IRS Mandate

Investor action plan with monitors showing Coinbase portfolio and tax software with Feb 17 deadline on calendar

Starting January 1, 2025, the IRS banned the universal wallet method under Revenue Procedure 2024-28. This means:

→ Each wallet and exchange is treated as a separate tax account
→ Cost basis cannot be pooled across platforms
→ FIFO is the default if you don't elect Specific Identification
→ Coinbase can only track basis for crypto bought and sold within Coinbase

What This Means for Coinbase Users Specifically

SituationCoinbase Can Track Basis?Your Action Required
Bought BTC on Coinbase → Sold on Coinbase✅ YesVerify accuracy, choose Spec ID if beneficial
Bought BTC on Kraken → Transferred to Coinbase → Sold❌ No — shows $0 basisManually calculate basis from Kraken records
Received BTC from mining → Sent to Coinbase → Sold❌ NoUse FMV at time of mining as basis
Bought BTC on Coinbase → Transferred to Ledger → Sold on Kraken❌ Not Coinbase's problemTrack basis from original Coinbase purchase
Staking rewards earned on Coinbase → Sold✅ PartialVerify FMV at time rewards were received
Airdrop received in Coinbase wallet → Sold❌ Likely missingRecord FMV at time of airdrop
πŸ’‘ Critical Insight: Coinbase holds more crypto than any other company — over 12% of all crypto globally. But their 1099-DA can only track cost basis for assets bought directly on Coinbase. If you've ever transferred crypto in from any other source, the basis is on you.

πŸ“Œ Complete Per-Wallet Migration Guide

Step-by-step instructions, software comparison, and 20 FAQs

Per-Wallet Cost Basis Guide →

6. COIN Stock Down 68% — Tax-Loss Harvesting Opportunity

This section is for investors who hold COIN stock (not just crypto on Coinbase). With COIN trading at $141 — down 68% from its $444 all-time high — there's a significant tax-loss harvesting opportunity.

Purchase PriceCurrent PriceLoss per Share100 Shares Loss
$444 (ATH)$141‑$303‑$30,300
$350$141‑$209‑$20,900
$250$141‑$109‑$10,900
$200$141‑$59‑$5,900
⚠️ IMPORTANT: Wash Sale Rule APPLIES to COIN Stock
Unlike crypto, COIN is a publicly traded stock. The wash sale rule applies. If you sell COIN at a loss, you cannot repurchase it within 30 days before or after the sale — or the loss is disallowed. This is the opposite of crypto, where the wash sale rule does not currently apply.

Strategy: COIN Losses Can Offset Crypto Gains

Here's where it gets powerful: Capital losses from COIN stock can offset capital gains from crypto sales. If you have $20,000 in crypto gains and $20,000 in COIN stock losses, they cancel out — $0 tax. Any excess loss up to $3,000 offsets ordinary income. Remaining losses carry forward to future years.

πŸ“‰ Crypto Tax-Loss Harvesting Guide

BTC down 48% from ATH — learn the complete strategy

Tax-Loss Harvesting Mega Guide →

7. 5-Step Action Plan Before April 15

Step 1: Receive and Review Your 1099-DA (By Feb 17)

Check your Coinbase account → Tax Documents section. Download the 1099-DA when available. Review every transaction listed. Flag any that show $0 cost basis — these need manual correction.

Step 2: Export Your Full Transaction History

Go to Coinbase → Settings → Taxes → Download Reports. Export your complete transaction history CSV. This includes transfers, staking rewards, and trades that may not appear on the 1099-DA.

Step 3: Import into Crypto Tax Software

Use a dedicated crypto tax tool to calculate your actual cost basis per wallet:

SoftwarePer-Wallet TrackingSpec ID / HIFOStarting Price
CoinTracker$59/yr (100 txns)
Koinly$49/yr (100 txns)
CoinLedger$49/yr
TaxBitFree (basic)
Awaken Tax$50/yr

Step 4: Reconcile 1099-DA with Your Records

Compare the 1099-DA gross proceeds against your tax software's output. If numbers don't match, use Form 8949 Column (e) to explain the difference. Common reasons for mismatch: transferred-in crypto ($0 basis on 1099-DA), missing staking rewards, fee calculations.

Step 5: File Form 8949 + Schedule D

Report all crypto disposals on Form 8949. Use Column (f) Code B for short-term and Code E for long-term if cost basis was NOT reported on the 1099-DA. Transfer totals to Schedule D. If you have COIN stock losses, report those on a separate 8949 from your broker's 1099-B.

✅ Pro Tip: If you have more than 50 crypto transactions, most tax software generates the Form 8949 automatically. You can attach it as a supporting PDF to your tax return. TurboTax, H&R Block, and FreeTaxUSA all accept crypto tax software imports.

8. FAQ: 15 Critical Questions About Coinbase Q4 and Your Taxes

Q1: Did Coinbase actually lose $667 million?

Yes, on a GAAP (Generally Accepted Accounting Principles) basis. However, $718M came from unrealized crypto portfolio losses and $395M from strategic investment declines. On an adjusted basis, the core business generated $178M in net income and $566M in EBITDA.

Q2: Is Coinbase in financial trouble?

No. Coinbase holds $11.3 billion in cash and cash equivalents, repurchased $1.7 billion of its own stock, and has $2.3 billion remaining in buyback authorization. The company guided Q1 2026 transaction revenue of approximately $420M through Feb 10.

Q3: When will I receive my Coinbase 1099-DA?

The IRS deadline for brokers to deliver 1099-DA to taxpayers is February 17, 2026. Check your Coinbase account under Settings → Tax Documents. It may also arrive by mail or email.

Q4: Does the Coinbase 1099-DA include cost basis?

Not for 2025 transactions. The 1099-DA only reports gross proceeds this year. Cost basis reporting becomes mandatory for "covered" digital assets starting with transactions on or after January 1, 2026. IRS Source →

Q5: What happens if I just file using the 1099-DA numbers?

The IRS will treat your sale proceeds as 100% gain because no cost basis is shown. For example, selling 1 BTC at $66,000 would appear as a $66,000 taxable gain with a $15,840 tax bill at 24%. You must report your own cost basis on Form 8949.

Q6: What about crypto I transferred into Coinbase from another wallet?

Coinbase cannot track cost basis for transferred-in crypto. The 1099-DA will show $0 basis for these assets. You must use records from the original purchase platform to determine and report the correct cost basis.

Q7: Can I use HIFO (Highest In, First Out) on Coinbase?

Coinbase's default reporting may use FIFO, but you can elect Specific Identification (which includes HIFO) on your tax return. The key is proper documentation showing which specific lots you sold. Crypto tax software like CoinTracker and Koinly automate this.

Q8: I hold COIN stock at a loss. Can I harvest the loss?

Yes, but the wash sale rule applies to stocks. If you sell COIN at a loss, you cannot repurchase COIN (or a "substantially identical" security) within 30 days before or after the sale. COIN losses can offset crypto gains and up to $3,000 of ordinary income.

Q9: Does the wash sale rule apply to my crypto on Coinbase?

As of this writing (February 2026), the wash sale rule does not apply to cryptocurrency. You can sell BTC at a loss and buy it back immediately. However, Congress has proposed extending the rule to crypto — this could change in a future tax year.

Q10: What is the per-wallet cost basis rule?

Starting January 1, 2025, under Revenue Procedure 2024-28, you can no longer pool cost basis across all your wallets. Each exchange or wallet is treated as a separate tax account with its own cost basis tracking. IRS Rev. Proc. 2024-28 →

Q11: My 1099-DA shows transactions I don't recognize. What do I do?

This could be from automated conversions, staking rewards, or referral bonuses. Log into Coinbase and review your full transaction history. If you believe transactions are incorrect, contact Coinbase support and document everything before filing.

Q12: Does Coinbase report to the IRS even if I don't get a 1099-DA?

Yes. Coinbase files the 1099-DA with the IRS regardless of whether you receive your copy. You are still obligated to report all crypto transactions. Not receiving the form is not a valid excuse for not reporting.

Q13: Are Coinbase staking rewards taxable?

Yes. Staking rewards are taxable as ordinary income at fair market value when received. The cost basis for future sale is the FMV at the time the reward was issued. Coinbase earned $152M in blockchain rewards revenue in Q4, down 18% QoQ.

Q14: What about international reporting — CARF 2027?

Starting 2027, the Crypto Asset Reporting Framework (CARF) will enable 48 countries to automatically exchange crypto transaction data. U.S. taxpayers using offshore exchanges will face much tighter scrutiny. Coinbase, as a U.S.-regulated exchange, already reports to the IRS. CARF 2027 Guide →

Q15: Should I switch from Coinbase to another exchange for tax purposes?

Switching exchanges doesn't solve the tax problem — it creates more complexity. Every transfer between exchanges is a potential tracking event. The real solution is proper documentation and per-wallet cost basis tracking using crypto tax software, regardless of which exchange you use.

πŸ“š Related Guides

πŸ”” Stay Ahead of IRS Changes

New crypto tax rules drop every month. Get our guides delivered free.

Browse All Guides at Legal Money Talk →
Disclaimer: This article is for informational and educational purposes only. It does not constitute tax, legal, or financial advice. Tax laws are complex, change frequently, and vary by jurisdiction. Consult a qualified tax professional (CPA, tax attorney, or enrolled agent) before making any tax-related decisions. The author and Legal Money Talk are not responsible for any actions taken based on this content. All financial figures are based on publicly available data from Coinbase's Q4 2025 shareholder letter filed February 12, 2026. Cryptocurrency investments carry significant risk, including the risk of total loss. Past performance is not indicative of future results.

Per-Wallet Cost Basis 2026: The New IRS Rule That Changes Everything for Crypto Investors — Complete Migration Guide Before 1099-DA Deadline

DC

Davit Cho

Global Asset Strategist & Crypto Tax Compliance Expert

πŸ“Š Verified Against: IRS Final Regulations (TD 10000), Revenue Procedure 2024-28, CoinTracker 2026 Tax Guide, Fidelity Digital Assets Report
πŸ“… Published: February 13, 2026  |  Last Updated: February 13, 2026
✉️ Contact: davitchh@proton.me

⚡ 13+ years experience in Global Asset Strategy & International Tax Enforcement

 


Per-Wallet Cost Basis 2026: The New IRS Rule That Changes Everything for Crypto Investors

On January 1, 2025, the IRS quietly ended the most popular method of tracking crypto cost basis. If you missed it, you're already behind — and the consequences hit your 2025 tax return filed this April.

The "Universal Method" is dead. Per-wallet cost basis tracking is now mandatory.

Under Revenue Procedure 2024-28, the IRS now requires every crypto investor to calculate cost basis separately for each wallet and exchange — Coinbase, Kraken, MetaMask, Ledger, Binance — each one is its own isolated cost basis universe.

If you don't designate which specific units you're selling at the time of each transaction, the IRS defaults to FIFO (First-In, First-Out) — which in a market where Bitcoin has crashed from $109,000 to ~$66,000, means you're selling your cheapest coins first and paying maximum taxes on gains that barely exist.

🚨 Critical Deadline: February 17, 2026

U.S. crypto brokers must send you Form 1099-DA by February 17, 2026 — just 4 days from now. This is the first year this form exists. For 2025 transactions, it reports gross proceeds only. Starting January 1, 2026, brokers will also report cost basis — and if you haven't set up per-wallet tracking, the broker defaults to FIFO, potentially inflating your taxable gains by thousands.

Source: IRS Newsroom — Reminders for Taxpayers About Digital Assets (January 28, 2026)

This guide is the complete migration playbook: what changed, why it costs you money, how to switch to Specific Identification (HIFO) before each sale, and the exact software setup to stay compliant. As of February 13, 2026, Bitcoin is trading at approximately $66,000 — down 48% from its all-time high of $109,000 — making cost basis strategy more critical than ever.

Section 1: What Changed — Universal Method Is Dead

Before January 1, 2025, most crypto investors used the "Universal Method" — a single pool of cost basis across all wallets and exchanges. If you bought 1 BTC on Coinbase for $30,000 and another 1 BTC on Kraken for $60,000, the Universal Method treated them as one pool with an average basis of $45,000 per BTC.

That's over.

Under IRS Final Regulations (Treasury Decision 10000) published June 28, 2024, and Revenue Procedure 2024-28 released the same day, the IRS mandated that starting January 1, 2025:

  • Cost basis must be tracked separately per wallet and per exchange account
  • The Universal Method (pooling across wallets) is no longer permitted
  • If you don't specify which units you're selling, the IRS applies FIFO by default within each wallet
  • Taxpayers had until December 31, 2024 to use the Safe Harbor provision to allocate existing "unused basis" across wallets

⚠️ If You Missed the December 31, 2024 Safe Harbor Deadline

You're not out of options — but you've lost the ability to choose how to allocate your existing basis. The IRS will default to FIFO within each wallet for all pre-2025 holdings. This could mean higher taxes if your oldest purchases have the lowest basis. Consult a crypto-specialized CPA immediately if you have significant holdings across multiple wallets.

Section 2: Per-Wallet Cost Basis Explained (With Examples)

Under the new per-wallet system, every wallet and exchange account is treated as an isolated tax lot universe. Here's what that means in practice:

πŸ“Š Example: Sarah's 3-Wallet BTC Portfolio

Wallet/Exchange BTC Held Purchase Price Cost Basis per BTC
Coinbase 0.5 BTC Bought at $30,000 (2022) $30,000
Kraken 0.5 BTC Bought at $95,000 (Jan 2025) $95,000
Ledger (Hardware) 1.0 BTC Transferred from Coinbase (originally $30,000) $30,000

Old Universal Method: Sarah's total pool = 2 BTC with blended average basis of $46,250 per BTC. If she sells 0.5 BTC at $66,000, gain = $19,750.

New Per-Wallet Method: If Sarah sells 0.5 BTC from Coinbase, basis = $30,000, gain = $36,000. If she sells 0.5 BTC from Kraken, basis = $95,000, loss = -$29,000.

πŸ’‘ The Strategic Insight

Under per-wallet rules, which wallet you sell from completely changes your tax outcome. Selling from Kraken generates a $29,000 tax loss. Selling from Coinbase creates a $36,000 taxable gain. Same asset, same sale price — wildly different tax results. This is why per-wallet awareness is now critical for every single crypto sale.

Section 3: Universal vs Per-Wallet — Before & After Comparison


Factor Universal Method (Before 2025) Per-Wallet Method (2025+)
Cost Basis Pool All wallets merged into one pool Each wallet/exchange = separate pool
FIFO Default Applied across all holdings globally Applied within each individual wallet
Specific ID (HIFO) Pick any lot from any wallet Can only pick lots within the selling wallet
Transfer Between Wallets No tax impact (same pool) Cost basis must travel with the asset
Complexity Low — one spreadsheet High — requires software per wallet
Tax Optimization Easier to cherry-pick lots Requires pre-sale planning per wallet
IRS Authority Permitted until Dec 31, 2024 Rev. Proc. 2024-28 + TD 10000

Section 4: The FIFO Trap — How Default Rules Cost You Thousands

FIFO (First-In, First-Out) is the IRS default if you don't specifically identify which units you're selling. Under FIFO, the oldest units in each wallet are sold first — and for most crypto investors who started buying in 2020-2022, those are the cheapest units, meaning maximum taxable gains.

πŸ’° Real Example: The FIFO Tax Penalty

Scenario: Mike holds 2 BTC on Coinbase. He sells 1 BTC on February 13, 2026 at $66,000.

Lot Purchase Date Cost Basis Sale Price Gain / Loss
Lot A (FIFO Default) March 2021 $35,000 $66,000 +$31,000 gain
Lot B (Specific ID / HIFO) October 2025 $109,000 $66,000 -$43,000 loss

🚨 The $74,000 Swing

FIFO default = $31,000 taxable gain → at 37% bracket = $11,470 in taxes owed

Specific ID (HIFO) = $43,000 deductible loss → offsets other gains + $3,000 ordinary income deduction → potential $15,910 in tax savings

Total swing: $27,380 in real tax dollars — just by choosing which lot to sell. Same BTC. Same sale price. Different lot = completely different tax outcome.

According to CoinTracker's 2026 tax guide, taxpayers who use Specific Identification (HIFO) instead of FIFO save an average of $5,600 per year in crypto taxes. For high-volume traders, the savings can exceed $50,000 annually.

Section 5: Step-by-Step Migration Guide (Rev. Proc. 2024-28)

Whether you used the Safe Harbor before December 31, 2024 or not, here's the complete workflow for filing your 2025 taxes correctly under the new per-wallet rules:

✅ Step 1: Inventory Every Wallet and Exchange Account

List every location where you hold or held crypto in 2025. This includes centralized exchanges (Coinbase, Kraken, Gemini, Binance.US), foreign exchanges (Binance.com, Bybit, OKX), hardware wallets (Ledger, Trezor), software wallets (MetaMask, Phantom, Trust Wallet), and DeFi protocols where you deposited or staked tokens.

✅ Step 2: Export Full Transaction History From Each Wallet

For each exchange, download the complete 2025 transaction CSV. For self-custody wallets, export from the relevant block explorer (Etherscan, Solscan, Blockchain.com). Include all trades, swaps, staking rewards, airdrops, and transfers.

✅ Step 3: Import Into Per-Wallet-Compatible Tax Software

Use software that supports per-wallet cost basis tracking. Import each wallet separately. The software must maintain isolated cost pools per wallet — not merge them.

✅ Step 4: Choose Your Cost Basis Method Per Wallet

For each wallet, you can choose:

Method How It Works Best For Tax Impact
FIFO (Default) Sell oldest units first Almost no one — worst for tax efficiency Highest taxes (sells cheapest lots first)
HIFO (via Spec-ID) Sell highest-cost units first Most investors — minimizes gains Lowest taxes (sells most expensive lots first)
LIFO Sell newest units first Short-term loss harvesting Varies — good in rising markets
Specific Identification Choose exact lot per trade Advanced traders, CPAs Maximum flexibility

✅ Step 5: Track Transfers Between Wallets

When you transfer crypto from one wallet to another (e.g., Coinbase → Ledger), the cost basis must travel with the asset. A transfer is not a taxable event, but you must document the cost basis of each unit transferred. This is the #1 area where investors make mistakes under the new rules.

✅ Step 6: Generate Form 8949 and Schedule D

Your crypto tax software will generate Form 8949 (individual transactions) and Schedule D (summary). For 2025 returns, use Box C (short-term, no 1099-DA) or Box F (long-term, no 1099-DA) for foreign exchange and self-custody wallet transactions. For U.S. exchange transactions where you received a 1099-DA, use Box A or Box D.

✅ Step 7: Reconcile Against 1099-DA (If Received)

Starting February 17, 2026, U.S. brokers will send Form 1099-DA. For 2025 transactions, this form reports gross proceeds only (not cost basis). Compare this against your own calculations. If there's a discrepancy, attach an explanation statement to your return.

πŸ’‘ Pro Tip: The "Covered vs Uncovered" Distinction

Starting January 1, 2026, crypto purchased and held within the same broker account becomes a "covered security." Brokers must then report cost basis to the IRS. Any crypto acquired before 2026, or held in a different wallet from where it was purchased, is "uncovered" — meaning you are responsible for calculating and reporting cost basis. This distinction becomes critical for your 2026 transactions (filed in 2027).

Section 6: Crypto Tax Software Comparison for Per-Wallet Tracking


Not all crypto tax software handles per-wallet tracking correctly. Here's the 2026 comparison focused specifically on Rev. Proc. 2024-28 compliance:

Software Per-Wallet Tracking? HIFO Support? Transfer Basis Tracking? Pricing (2026)
CoinTracker ✓ YES (Native) ✓ YES ✓ YES $59–$1,999/yr
Koinly ✓ YES (Updated) ✓ YES ✓ YES $49–$999/yr
CoinLedger ✓ YES (Updated) ✓ YES ✓ YES $49–$299/yr
TaxBit ✓ YES ⚠ Limited ✓ YES $50–$500/yr
Awaken Tax ✓ YES ✓ YES ✓ YES $99–$599/yr

πŸ’‘ Our Recommendation

For most investors: CoinTracker or Koinly — both have native per-wallet tracking, HIFO support, and handle transfer basis correctly. Koinly is slightly cheaper; CoinTracker integrates better with TurboTax.

For DeFi-heavy users: Koinly or Awaken Tax — better at parsing complex DeFi interactions (liquidity pools, yield farming, cross-chain bridges).

For high-volume traders (1,000+ transactions): CoinTracker Ultra or TaxBit Enterprise — built for scale and CPA collaboration.

Section 7: The 1099-DA Connection — What Brokers Report in 2026

Form 1099-DA is the IRS's new weapon for crypto tax enforcement, and it's directly linked to the per-wallet cost basis rule. Here's the timeline:

Tax Year Form Sent What Brokers Report Your Action
2025 (Current) By Feb 17, 2026 Gross proceeds ONLY (no cost basis) Self-calculate cost basis per wallet
2026 (Next Year) By Feb 2027 Gross proceeds + Cost basis (covered assets only) Reconcile broker basis with your records
2027+ (CARF Era) By Feb 2028 All data + Foreign exchange auto-reporting Full reconciliation across domestic + foreign

⚠️ The 1099-DA Cost Basis Trap for 2026

Starting January 1, 2026, brokers will default to FIFO for cost basis reporting on covered assets unless you explicitly tell them otherwise. If you don't log into Coinbase, Kraken, or Gemini before your first 2026 sale and select "Specific Identification" as your accounting method, the broker will lock in FIFO — and the 1099-DA sent to the IRS will reflect FIFO calculations. Correcting this after the fact is extremely difficult.

Section 8: 7 Common Mistakes That Trigger IRS Audits

These are the most frequent errors IRS agents flag when reviewing crypto returns under the new per-wallet rules:

❌ Mistake #1: Still Using Universal Method for 2025 Returns

The Universal Method ended December 31, 2024. Filing your 2025 return with pooled cross-wallet basis is non-compliant and will trigger a mismatch if the IRS compares your return against broker-reported data.

❌ Mistake #2: Not Tracking Basis on Wallet-to-Wallet Transfers

When you move BTC from Coinbase to Ledger, the cost basis must follow. If your Ledger shows $0 basis because you didn't track the transfer, you'll report 100% of the sale as gain — massively overpaying taxes.

❌ Mistake #3: Ignoring Foreign Exchange Transactions

Binance.com, Bybit, and OKX don't send 1099-DA, but the IRS can trace your transactions via blockchain analytics. Every foreign exchange transaction requires self-reporting on Form 8949 with per-wallet basis calculated independently.

❌ Mistake #4: Defaulting to FIFO Without Realizing It

If you don't explicitly select Specific Identification (HIFO) before each sale, the IRS applies FIFO. For someone who bought BTC at $20,000 in 2022 and $100,000 in 2025, FIFO sells the $20,000 lot first — creating a taxable gain even if the current price is below your latest purchase.

❌ Mistake #5: Missing Staking, Airdrop, and DeFi Income

Staking rewards and airdrops received in any wallet have a cost basis equal to their fair market value at the time of receipt. These must be tracked per wallet as ordinary income — and then separately as capital gain/loss when sold.

❌ Mistake #6: Inconsistent Method Across Tax Years

If you used FIFO in 2024 but switch to HIFO in 2025 without proper documentation, the IRS may challenge your basis calculations. Maintain a written record of your chosen method for each wallet, each year.

❌ Mistake #7: Not Reconciling 1099-DA With Self-Calculated Basis

When your 1099-DA arrives (by Feb 17), compare the gross proceeds figure against your crypto tax software output. Any mismatch — even small — can auto-flag your return in the IRS matching system.

Section 9: FAQ — 20 Critical Questions Answered

❓ Q1: What is per-wallet cost basis?

It means you must calculate cost basis separately for each wallet and exchange account. BTC on Coinbase has one basis; BTC on Ledger has another — even if it's the same Bitcoin.

❓ Q2: When did the Universal Method end?

December 31, 2024. Starting January 1, 2025, per-wallet tracking is mandatory under Rev. Proc. 2024-28.

❓ Q3: What is the Safe Harbor, and is it too late?

The Safe Harbor allowed you to allocate existing "unused basis" across your wallets by December 31, 2024. If you missed it, the IRS defaults to FIFO within each wallet for pre-2025 holdings.

❓ Q4: What happens if I don't specify which lot I'm selling?

The IRS applies FIFO — the oldest lot in that specific wallet is sold first. In a crash market, this typically means selling your cheapest lots and paying maximum taxes on gains.

❓ Q5: Can I use HIFO for crypto?

HIFO (Highest-In, First-Out) is a form of Specific Identification. The IRS allows Specific Identification if you designate the specific units being sold at or before the time of the transaction. Most crypto tax software does this automatically when you select HIFO.

❓ Q6: Does a wallet-to-wallet transfer trigger taxes?

No. Transfers between your own wallets are not taxable events. However, the cost basis must travel with the asset, and you must document the transfer to avoid losing basis information.

❓ Q7: How do I track basis on DeFi protocols?

DeFi interactions (swaps on Uniswap, deposits into Aave, LP token minting) each create separate taxable events. Your DeFi wallet address is a separate cost basis pool. Use Koinly or Awaken Tax, which have the best DeFi parsing engines.

❓ Q8: What about NFTs — are they per-wallet too?

Yes. NFTs are digital assets and subject to the same per-wallet rules. Each NFT in each wallet has its own cost basis. NFTs are taxed as collectibles at up to 28% for long-term holdings.

❓ Q9: Does the per-wallet rule apply to staking rewards?

Yes. Staking rewards received in a wallet have a cost basis equal to FMV at receipt. That basis is tied to that specific wallet. If you later move staked tokens to another wallet, the basis must follow.

❓ Q10: Can I change my cost basis method mid-year?

You can use different methods for different wallets. However, within a single wallet, you should be consistent throughout the tax year. Document any changes.

❓ Q11: What if my exchange doesn't support Specific ID?

Export your data to a crypto tax tool that does. CoinTracker, Koinly, and CoinLedger all allow you to apply HIFO/Specific ID regardless of what the exchange supports natively.

❓ Q12: How does this affect tax-loss harvesting?

Per-wallet rules make tax-loss harvesting more strategic. You must harvest from the specific wallet that holds the high-basis lots. You can't sell "your overall BTC position at a loss" — you sell specific lots in specific wallets.

❓ Q13: What about crypto in retirement accounts (IRA/401k)?

Crypto held in tax-advantaged retirement accounts (self-directed IRAs) is not subject to annual capital gains reporting. However, distributions are taxed as ordinary income. The per-wallet rule applies to taxable accounts only.

❓ Q14: Does this apply to Bitcoin ETFs (IBIT, FBTC)?

No. Bitcoin ETF shares are treated like stocks and reported on standard 1099-B forms. The per-wallet rule applies to direct crypto holdings only — coins in wallets and exchanges.

❓ Q15: What if I used a spreadsheet — is that acceptable?

Technically yes, if it accurately tracks per-wallet basis with dates, amounts, and lot identification. In practice, the IRS prefers software-generated reports. A spreadsheet with errors is a fast path to audit.

❓ Q16: Do the wash sale rules apply to crypto yet?

As of February 2026, crypto is still exempt from wash sale rules. You can sell BTC at a loss and immediately repurchase. However, Congress may close this loophole. Track legislative changes carefully.

❓ Q17: I have crypto on 10+ exchanges. How do I manage this?

Use CoinTracker or Koinly to import all 10+ exchanges simultaneously. The software maintains separate cost pools automatically. Consolidating to fewer exchanges reduces complexity going forward.

❓ Q18: What's the penalty for incorrect cost basis?

A 20% accuracy-related penalty on the underpayment (26 U.S.C. § 6662). If the IRS determines fraud, the penalty increases to 75%. Good-faith efforts documented with software logs provide strong penalty protection.

❓ Q19: Should I consolidate all crypto into one wallet?

From a tax simplification standpoint, yes — fewer wallets = fewer cost pools to track. From a security standpoint, no — diversification across wallets reduces hack risk. Balance both.

❓ Q20: Where can I read the actual IRS guidance?

Revenue Procedure 2024-28: irs.gov/pub/irs-drop/rp-24-28.pdf
Treasury Decision 10000: IRS Final Regulations for Digital Asset Reporting
IRS Digital Assets Page: irs.gov/filing/digital-assets

⚖️ Legal Disclaimer

This article is provided for educational and informational purposes only and does not constitute legal, tax, or financial advice. Tax laws are complex and change frequently. Davit Cho and LegalMoneyTalk do not provide personalized tax advice. Always consult a qualified CPA, Enrolled Agent, or tax attorney before making tax-related decisions. Information is verified against IRS Rev. Proc. 2024-28, Treasury Decision 10000, CoinTracker and Koinly 2026 guides, and Fidelity Digital Assets reports as of February 13, 2026.

⚠️ 1099-DA Deadline: February 17, 2026 — 4 Days Left

Your broker is about to send Form 1099-DA to you and the IRS. If your per-wallet cost basis isn't set up, the IRS gets FIFO numbers — and you pay maximum taxes. Act now.

πŸ“„ Read the 1099-DA Survival Guide Now

Questions? Email Davit Cho at davitchh@proton.me
Published: February 13, 2026 | Last Updated: February 13, 2026

Per-Wallet Cost Basis 2026: The New IRS Rule That Changes Everything for Crypto Investors — Complete Migration Guide Before 1099-DA Deadline

⚠️ This article has been updated → Read the latest version here

✍️ Written by Davit Cho

Crypto Tax Specialist & CEO at JejuPanaTek

13+ Years Experience | Patent #10-1998821 | IRS Compliance Expert

davitchh@proton.me

Per-Wallet Cost Basis 2026: The New IRS Rule That Changes Everything for Crypto Investors — Complete Migration Guide Before 1099-DA Deadline

Per-wallet cost basis 2026 IRS rule change infographic showing multiple crypto wallets connected to IRS building with different cost basis numbers

The IRS just killed the universal wallet method. Starting January 1, 2025, you can no longer pool your crypto across multiple exchanges and wallets for cost basis calculations. Every wallet, every exchange — each one is now its own separate tax universe.

This is the single biggest crypto tax rule change in a decade. And most investors don't even know it happened.

If you hold Bitcoin on Coinbase, Kraken, and a Ledger hardware wallet, you now need to track the cost basis for each platform independently. Sell from the wrong wallet without proper identification, and the IRS defaults you to FIFO (First In, First Out) — which in a volatile market like February 2026 could mean paying taxes on phantom gains you never actually realized.

Here's what makes this urgent: Form 1099-DA arrives by February 17, 2026 — just 7 days from now. Your exchange will report your transactions to the IRS. If your records don't match what they send, you'll get an automated notice. If you haven't migrated from universal to per-wallet tracking, your cost basis is likely wrong right now.

Forbes called the 2026 filing season a "minefield" for crypto investors. This guide is your map through it.

⚡ Quick Facts

  • Rule Change: Universal wallet method banned — effective January 1, 2025 (Rev. Proc. 2024-28)
  • New Requirement: Per-wallet/per-exchange cost basis tracking mandatory for all crypto disposals
  • Default Method: If you don't specifically identify lots, IRS applies FIFO automatically
  • Safe Harbor Deadline: December 31, 2024 (already passed — but migration steps still available)
  • 1099-DA Deadline: February 17, 2026 — exchanges report to IRS and you
  • Cost Basis on 1099-DA: Optional for 2025 transactions; mandatory starting 2026 transactions
  • Backup Withholding Risk: 24% of gross proceeds if TIN is missing or incorrect
  • BTC Price Today: ~$69,000 (down 45% from $126K ATH — cost basis accuracy matters more than ever)

1️⃣ Why This Rule Changes Everything

Before 2025, crypto investors could treat all their holdings of a single asset as one big pool — regardless of which wallet or exchange held them. If you had 3 BTC on Coinbase and 2 BTC on a Ledger, you could calculate cost basis as if all 5 BTC lived in the same place. This was called the "universal method" or "universal wallet."

That's dead now.

The IRS finalized Treasury regulations in July 2024 (implemented via Revenue Procedure 2024-28) requiring that all crypto cost basis tracking be done on a per-wallet, per-account basis starting January 1, 2025. This means:

⚠️ Key Change: When you sell crypto from a specific wallet or exchange, your gain/loss calculation must use ONLY the cost basis from that specific wallet. You cannot reference purchases made on a different platform, even for the exact same asset.

This fundamentally changes how every multi-exchange investor — and that's most of us — calculates their taxes. If your highest-cost BTC lots sit on Coinbase but you sell from Kraken, you can't use those Coinbase lots to reduce your Kraken gain. Each platform's cost basis is isolated.

Why does this matter in February 2026? Because Bitcoin just crashed 45% from $126K to $69K. Cost basis accuracy is the difference between a massive tax-loss harvesting opportunity and accidentally triggering gains. If your per-wallet basis isn't properly allocated, you could show a gain on one exchange while sitting on losses at another — and miss the deduction entirely.

2️⃣ Universal Method vs Per-Wallet: What Changed and Why

Let's get precise about what changed and why the IRS made this move.

The Old Way: Universal Method

Under the universal method, all units of the same cryptocurrency across all your wallets were treated as a single inventory pool. If you bought 1 BTC at $30K on Coinbase in 2021 and 1 BTC at $100K on Kraken in 2024, and you sold 1 BTC from Kraken, you could choose to use the $100K cost basis (Specific ID) or the $30K cost basis (FIFO) — regardless of which exchange executed the sale. The physical location of the asset didn't matter for tax purposes.

The New Way: Per-Wallet Tracking

Under per-wallet tracking, each wallet or exchange account is its own tax silo. The cost basis from Coinbase stays on Coinbase. The cost basis from Kraken stays on Kraken. If you sell from Kraken, you can only use Kraken's cost basis for that calculation. Period.

FeatureUniversal Method (Pre-2025)Per-Wallet Method (2025+)
Cost basis scopeAll wallets combinedEach wallet/exchange separately
Lot selectionChoose any lot from any walletOnly lots within the selling wallet
Transfer between walletsNo cost basis impactCost basis travels with the asset
FIFO defaultApplied across all holdingsApplied within each wallet only
Spec ID flexibilityCross-wallet identification allowedOnly within-wallet identification
IRS tracking difficultyLow (aggregated)High (wallet-level granularity)
Investor record-keeping burdenModerateSignificantly higher
StatusBANNEDMANDATORY

Why the IRS Made This Change

The IRS is aligning crypto with how stocks and securities have always been reported. When you sell shares of Apple on Fidelity, you can't use cost basis from your Schwab account. The same logic now applies to crypto. This change was part of the broader push toward Form 1099-DA standardization — exchanges need to report per-account data, so investors need to track per-account data.

The secondary goal: closing the loophole where investors strategically picked the highest-cost lots from any wallet to minimize gains while selling from a different wallet with lower-cost lots. The IRS saw this as basis manipulation.

3️⃣ Before & After: Same Portfolio, Different Tax Bills

Before and after comparison of universal wallet method versus per-wallet cost basis tracking for crypto tax 2026

Let's run a real example to show how dramatically this changes your tax bill.

Your Portfolio

LocationAssetQuantityPurchase PriceCost BasisPurchase Date
CoinbaseBTC1$100,000$100,000Jan 2025
KrakenBTC1$40,000$40,000Mar 2023
Ledger (hardware)BTC1$70,000$70,000Jun 2024

Action: You sell 1 BTC from Kraken at $69,000 (today's price).

Scenario A: Under the Old Universal Method

You could use Specific ID to choose the Coinbase lot ($100K basis) even though you're selling from Kraken. Result: $69K - $100K = -$31,000 loss. That's a $31K tax deduction.

Scenario B: Under the New Per-Wallet Method

You sell from Kraken, so you must use Kraken's cost basis. Kraken only has the $40K lot. Result: $69K - $40K = +$29,000 gain. That's $29K in taxable income.

πŸ’₯ The Difference: Same sale. Same portfolio. Under the old rules = $31K loss (tax refund). Under the new rules = $29K gain (tax bill). That's a $60,000 swing in your taxable position — just because of which method applies.

What Should You Have Done?

If you wanted to harvest a loss, you should have sold from Coinbase (where your $100K lot is) — not Kraken. Or, before the sale, you should have transferred the Coinbase BTC to Kraken (the cost basis travels with the asset) and then sold from Kraken using the $100K basis lot.

This is why understanding per-wallet tracking isn't optional — it's the difference between a refund and a bill.

4️⃣ The FIFO Trap: How Default Accounting Destroys Your Tax Bill

Here's where most investors get burned: if you don't specifically identify which lots you're selling at the time of the transaction, the IRS automatically applies FIFO (First In, First Out) — within each wallet.

Why FIFO Is Usually the Worst Method in 2026

In a market that went from $30K (2023) to $126K (Oct 2025) and back to $69K (Feb 2026), your oldest lots typically have the lowest cost basis. FIFO sells those first, creating the largest possible taxable gain.

MethodWhich Lot Sold FirstCost Basis UsedGain/Loss on $69K SaleTax Impact
FIFO (Default)Oldest lot first$40,000 (2023)+$29,000 gainYou owe taxes
LIFONewest lot first$100,000 (2025)-$31,000 lossYou get a deduction
HIFOHighest-cost lot first$100,000 (2025)-$31,000 lossYou get a deduction
Spec IDYou chooseYour choiceYou control itMaximum flexibility
⚡ Critical Rule (Effective Jan 1, 2025): You must specify your cost basis method BEFORE or at the time of the transaction. You cannot retroactively change from FIFO to Spec ID after the trade. If you traded in 2025 without selecting a method, the IRS considers it FIFO — permanently for those transactions.

How to Avoid the FIFO Trap

Set your preferred accounting method (HIFO or Spec ID) in your exchange settings before executing any trades. On Coinbase, this is under Tax Settings. On Kraken, configure it in your account preferences. For DeFi and hardware wallets, use crypto tax software (CoinTracker, Koinly, TaxBit) to specify your method and maintain contemporaneous records.

If you've already traded in 2025 or 2026 without selecting a method, those transactions default to FIFO. For future transactions, set up Spec ID immediately to regain control.

5️⃣ Step-by-Step Migration Guide (Even If You Missed the Safe Harbor)

The IRS offered a one-time "safe harbor" under Rev. Proc. 2024-28, allowing investors to allocate their existing cost basis across wallets by December 31, 2024. If you did this — great. If you missed it — you're not doomed, but you need to act immediately.

If You Completed the Safe Harbor (Before Dec 31, 2024)

Your cost basis is properly allocated across wallets. Verify your allocations in your crypto tax software. You're set for 2025 and 2026 reporting. No further migration needed.

If You Missed the Safe Harbor Deadline

The IRS applies a default allocation based on the assets physically present in each wallet as of January 1, 2025. Here's what that means practically:

StepActionDetail
1Inventory all wallets/exchangesList every platform where you held crypto as of Jan 1, 2025. Include centralized exchanges (Coinbase, Kraken, Binance US, Gemini), hardware wallets (Ledger, Trezor), software wallets (MetaMask, Phantom), and DeFi positions.
2Record holdings per walletFor each wallet, record the exact quantity of each crypto asset held on Jan 1, 2025.
3Assign cost basis to each walletMatch your historical purchase records to the assets in each wallet. If you bought 1 BTC on Coinbase and transferred it to Ledger, the cost basis from the Coinbase purchase follows it to Ledger.
4Choose accounting method per walletSet HIFO, LIFO, or FIFO for each wallet. HIFO is generally most tax-efficient. Configure this in your exchange settings AND your tax software.
5Import into crypto tax softwareImport all historical transactions from every wallet into CoinTracker, Koinly, or TaxBit. The software will calculate per-wallet cost basis automatically.
6Reconcile with 1099-DAWhen your 1099-DA arrives (by Feb 17, 2026), compare your software's data with what your exchange reported. Fix discrepancies immediately.
7Document your allocationSave your allocation methodology in writing. If the IRS asks how you assigned cost basis, you need a clear, defensible explanation.
✅ Pro Tip: Wallet-to-wallet transfers between your OWN accounts are NOT taxable events. The cost basis simply travels with the asset. But you MUST document the transfer — date, amount, sending wallet, receiving wallet, and the cost basis that moved. This is the #1 record most investors fail to keep.

6️⃣ Crypto Tax Software Comparison for Per-Wallet Tracking

Crypto tax software comparison for per-wallet cost basis tracking 2026 showing CoinTracker Koinly TaxBit dashboards with February 17 deadline

You cannot do per-wallet tracking manually if you have more than one exchange and a handful of transactions. Software is not optional — it's required infrastructure.

FeatureCoinTrackerKoinlyTaxBit
Per-wallet tracking✅ Full support✅ Full support✅ Full support
FIFO/LIFO/HIFO/Spec ID✅ All methods✅ All methods✅ All methods
1099-DA reconciliation✅ Auto-import✅ Manual + API✅ Native integration
DeFi/DEX support✅ Strong✅ Strong⚠️ Limited
Hardware wallet tracking✅ Ledger, Trezor✅ Ledger, Trezor⚠️ Via CSV only
Tax-loss harvesting dashboard✅ Dedicated TLH tool⚠️ Basic⚠️ Basic
Form 8949 export✅ Direct✅ Direct✅ Direct
TurboTax/H&R Block integration✅ Both✅ TurboTax✅ TurboTax
Free tier limit25 transactions10,000 transactionsNo free tier
Pricing (paid)$59–$599/yr$49–$279/yr$50–$500/yr
Best forActive traders, TLH focusMulti-exchange, DeFiInstitutional, 1099-DA
✅ Recommendation: If you're an active investor using multiple exchanges + DeFi + hardware wallets, Koinly offers the best value with its generous free tier and strong multi-wallet support. If tax-loss harvesting is your primary strategy right now (and it should be — BTC is down 45%), CoinTracker's dedicated TLH dashboard is the most powerful tool available. For institutional or high-volume traders who need native 1099-DA reconciliation, TaxBit is the industry standard.

7️⃣ 1099-DA Connection: What Your Exchange Reports vs What You Must Reconcile

Your exchange must send you Form 1099-DA by February 17, 2026. This is the first year this form exists. Here's what it contains and why per-wallet tracking matters for reconciliation.

What 1099-DA Reports (2025 Tax Year)

Field2025 Tax Year2026 Tax Year (Starting)
Gross proceeds✅ Required✅ Required
Cost basis⚠️ Optional✅ Required (for covered assets)
Date acquired⚠️ Optional✅ Required
Date sold✅ Required✅ Required
Short-term vs long-term⚠️ May not classify✅ Required
Wallet/account identifier✅ Per-account✅ Per-account

The Reconciliation Problem

Each exchange only sees transactions on its own platform. It doesn't know about your other wallets. This creates a critical gap:

If you transferred BTC from Coinbase to Kraken and then sold on Kraken, Coinbase's 1099-DA won't show the sale. Kraken's 1099-DA will show the sale but may not have your correct cost basis (because the BTC was originally purchased on Coinbase). Your crypto tax software is the single source of truth that connects these dots.

⚠️ IRS Matching: The IRS will receive copies of your 1099-DAs from every exchange. Their automated system matches these against your Form 8949. Mismatches trigger CP2000 notices (proposed tax adjustments). These notices assume you owe additional tax until you prove otherwise. Having per-wallet tracking in your tax software is your defense.

What You Should Do Before Feb 17

Import all 2025 transactions into your crypto tax software now. When your 1099-DA arrives, compare each line item. If the exchange's cost basis doesn't match your records (common for transferred assets), your records take precedence — but you must be able to substantiate them. Flag and document every discrepancy. If you file Form 8949 with different numbers than the 1099-DA, attach a statement explaining why.

8️⃣ Common Mistakes That Will Cost You Thousands

❌ Mistake #1: Treating Wallet Transfers as Taxable Events

Moving BTC from Coinbase to your Ledger is NOT a sale. It's a transfer. But if your records don't properly track it as a transfer, your tax software may treat it as a disposal (taxable) followed by a new acquisition (resetting your cost basis and holding period). This can create phantom gains and destroy your long-term capital gains status. Fix: Tag all self-transfers as "Transfer" in your tax software. Never categorize them as "Sell" or "Send."

❌ Mistake #2: Using Universal Method After Jan 1, 2025

If your tax software is still set to "universal" tracking, every calculation it produces is wrong. Any gains/losses from 2025 forward that were calculated with universal pooling will not match what the IRS expects. Fix: Switch your software to per-wallet mode immediately. Recalculate all 2025 transactions under the new method.

❌ Mistake #3: Forgetting DeFi Wallets

Your MetaMask wallet, Uniswap LP positions, staked ETH on Lido, wrapped tokens — all of these are separate "wallets" for cost basis purposes. If you only track centralized exchanges, you're missing a significant portion of your portfolio. Fix: Connect all DeFi wallets to your tax software via public address. Include staking, LP, and wrapped token positions.

❌ Mistake #4: Not Selecting a Cost Basis Method Before Trading

If you traded in 2025 or 2026 without explicitly selecting HIFO or Spec ID, the IRS treats those transactions as FIFO. You cannot retroactively change this. Fix: For all future trades, set your preferred method NOW in both your exchange settings and your tax software. For past trades already locked into FIFO, the damage is done — plan around it.

❌ Mistake #5: Ignoring the Backup Withholding Risk

If your exchange doesn't have a valid W-9 (TIN) on file, they may withhold 24% of your gross proceeds and send it to the IRS. For crypto, this could mean the exchange liquidates a portion of your holdings to generate cash for the withholding. Fix: Log into every exchange and verify your W-9 information is current and matches your IRS records exactly.

❌ Mistake #6: Mixing Personal and Business Wallets

If you receive crypto as payment for services (freelancing, consulting) and hold it in the same wallet as personal investments, cost basis gets tangled. Income receipts have a basis equal to FMV at receipt, while personal purchases have the original buy price. Fix: Maintain separate wallets for business income and personal investment. Track each independently.

9️⃣ FAQ: 20 Critical Per-Wallet Cost Basis Questions

❓ 1. Is the per-wallet rule already in effect?

Yes. It took effect January 1, 2025. All 2025 and 2026 transactions must use per-wallet cost basis tracking. The universal method is no longer permitted.

❓ 2. What's Revenue Procedure 2024-28?

Rev. Proc. 2024-28 is the IRS guidance that eliminated the universal wallet method and provided a one-time safe harbor (through Dec 31, 2024) for investors to allocate their existing cost basis across wallets before the new rules took effect.

❓ 3. I missed the Dec 31, 2024 safe harbor. Am I penalized?

No direct penalty for missing the safe harbor. However, the IRS applies a default allocation based on where your assets physically sat on Jan 1, 2025. If your highest-cost lots ended up in wallets you rarely sell from, your tax outcomes may be less favorable. You can still organize your records — you just can't retroactively use the safe harbor allocation flexibility.

❓ 4. Does the cost basis follow when I transfer crypto between my own wallets?

Yes. When you transfer crypto between wallets you control, it's not a taxable event. The original cost basis and holding period travel with the asset. But you MUST document the transfer with date, amount, and both wallet addresses.

❓ 5. What happens if I don't choose a cost basis method?

The IRS defaults to FIFO within each wallet. In a market that rose from $30K to $126K and then crashed to $69K, FIFO often creates the largest possible gain because it sells your oldest (cheapest) lots first.

❓ 6. Can I use HIFO or LIFO?

Yes — but only under Specific Identification. You must select the method before or at the time of the transaction and maintain contemporaneous records. You cannot retroactively apply HIFO or LIFO to trades already executed under FIFO.

❓ 7. How does this affect tax-loss harvesting?

Hugely. Under per-wallet rules, you need to sell from the wallet that holds your highest-cost lots to maximize your harvestable loss. If your $100K BTC is on Coinbase and your $40K BTC is on Kraken, selling from Coinbase generates a $31K loss while selling from Kraken generates a $29K gain. Same asset, opposite outcomes.

❓ 8. Does this apply to DeFi wallets like MetaMask?

Yes. Every self-custody wallet (MetaMask, Phantom, Trust Wallet) and every DeFi position is a separate "account" for per-wallet tracking. LP tokens, staked positions, and wrapped tokens each need independent cost basis tracking.

❓ 9. What about hardware wallets (Ledger, Trezor)?

Same rule. A Ledger is treated as a separate wallet. If you transfer BTC from Coinbase to Ledger, the Coinbase cost basis moves to Ledger. When you eventually sell from Ledger (by transferring back to an exchange), you use the original cost basis.

❓ 10. How do exchanges handle this on 1099-DA?

For 2025, cost basis on 1099-DA is optional. For 2026 transactions onward, exchanges must report cost basis for "covered" assets — meaning assets acquired AND sold on the same exchange. Assets transferred in from another wallet may show unknown basis on your 1099-DA. This is where your personal records fill the gap.

❓ 11. What's a "covered" vs "uncovered" digital asset?

A "covered" asset is one where the broker has enough information to report cost basis (bought and sold on the same exchange). An "uncovered" asset is one transferred in from another wallet — the exchange may not know the original cost basis. For uncovered assets, YOU are responsible for reporting accurate cost basis on Form 8949.

❓ 12. Can I still use one cost basis method for all wallets?

You can use the same METHOD (e.g., HIFO) across all wallets, but the calculation is done independently for each wallet. Using HIFO everywhere is a consistent approach, but the lots available for each sale depend on that specific wallet's holdings.

❓ 13. What about staking rewards?

Staking rewards are taxed as ordinary income at FMV when received. They enter the wallet where they're deposited with a cost basis equal to FMV at receipt. This creates a new lot in that specific wallet, tracked separately under per-wallet rules.

❓ 14. How do airdrops work under per-wallet rules?

Airdrops received are taxed as income at FMV when you gain "dominion and control." They enter the receiving wallet with that FMV as cost basis. If you sell the airdropped tokens later, the gain/loss is calculated against that wallet's airdrop basis.

❓ 15. What if my exchange doesn't support per-wallet tracking?

Most major exchanges (Coinbase, Kraken, Gemini) now support per-account tracking natively. If your exchange doesn't, export your transaction history as CSV and import into CoinTracker or Koinly. The software handles per-wallet calculations regardless of exchange capabilities.

❓ 16. I'm a US expat. Does this apply to me?

Yes. US citizens and green card holders are subject to worldwide income tax regardless of residence. Per-wallet tracking applies to all wallets globally — including foreign exchanges like Binance International, Bybit, and OKX. These foreign wallets also need FBAR/FATCA reporting if their value exceeds $10,000.

❓ 17. Does this affect crypto ETF holders (IBIT, GBTC)?

No. Crypto ETFs are traditional securities held in brokerage accounts. They follow standard stock cost basis rules and are reported on Form 1099-B, not 1099-DA. Per-wallet rules only apply to direct crypto holdings.

❓ 18. What's the penalty for getting cost basis wrong?

If you underreport income due to incorrect cost basis, the IRS can assess a 20% accuracy-related penalty on the underpayment. In cases of willful disregard, the penalty can reach 75%. Correct reporting from the start is far cheaper than penalties and interest.

❓ 19. Can I use a spreadsheet instead of software?

Technically yes, but realistically no — not if you have more than a handful of transactions across multiple wallets. The per-wallet calculations, lot identification, holding period tracking, and Form 8949 generation are complex. A $49/year Koinly subscription will save you hours and reduce errors dramatically.

❓ 20. Where can I read the IRS guidance directly?

Rev. Proc. 2024-28 is available on IRS.gov. The final Treasury regulations on digital asset broker reporting (TD 9989) were published in July 2024. Form 1099-DA instructions are in draft form at IRS.gov/pub/irs-dft/i1099da--dft.pdf. For IRS FAQ on digital assets, visit IRS.gov/individuals/international-taxpayers/frequently-asked-questions-on-digital-asset-transactions.

πŸ“š Related Articles You Must Read

⚖️ Legal Disclaimer

This article is for informational and educational purposes only. It does not constitute legal, tax, investment, or financial advice. Per-wallet cost basis tracking involves tax decisions that should be made with professional guidance.

Key regulatory references: Revenue Procedure 2024-28 — IRS safe harbor and per-wallet transition guidance; Treasury Decision 9989 (July 2024) — Final broker reporting regulations; IRS Notice 2014-21 — Crypto classified as property; IRC Section 1012 — Cost basis determination; Form 1099-DA — Digital Asset Proceeds From Broker Transactions.

Market data sources: CoinDesk, CoinMarketCap, Reuters, Forbes (February 10, 2026). Price data: Bitcoin ~$69,000, Ethereum ~$2,000 (approximate as of publication).

⚠️ WARNING: Crypto prices are extremely volatile. Cost basis calculations depend on accurate transaction records. Software tools referenced are for informational comparison — we have no affiliate relationships. Tax rules may change. Consult a qualified CPA, EA, or tax attorney before making any tax-related decisions.

Last Updated: February 10, 2026  |  Next Update: When IRS issues additional 1099-DA guidance or cost basis rule changes

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✉️ davitchh@proton.me

Davit Cho — Crypto Tax Specialist & CEO at JejuPanaTek
13+ Years Experience | Patent #10-1998821 | IRS Compliance Expert

Coinbase Q4 $667M Loss: What It Means for Your Crypto Taxes and 1099-DA

✍️ Written by Davit Cho Crypto Tax Specialist & CEO at JejuPanaTek 13+ Years Experience | Patent #10-1998821 | IRS Compliance...