The transition procedure in Revenue Procedure 2024-28 for allocating unused basis to assets held in wallets or accounts as of January 1, 2025.
Before 2025 many investors tracked basis across all wallets as one pool. The safe harbor let them allocate that pooled basis to specific wallets one time, before the first 2025 disposition or the 2025 return due date. Investors who did it have a clean per-wallet starting point; investors who did not are on the default rules.
Only if the allocation was made before your first 2025 disposition or the 2025 return due date, whichever came first. The window has closed for most taxpayers; late allocations fall back to the default per-wallet rules.
Source: Treas. Reg. 1.1012-1(j); Rev. Proc. 2024-28
Last reviewed September 18, 2026. Tax rules change; confirm current law before acting.
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