
Tracking and selecting digital asset tax lots separately within each wallet or account rather than across a single universal pool.
Universal (pre-2025): one pool of lots across every wallet; pick any lot for any sale. Wallet-by-wallet (2025 on): lots live where the coins live; a sale from a wallet uses that wallet's lots, FIFO by default.
Since January 1, 2025, this is the rule, not an option. A sale from one wallet can only be matched to lots in that wallet, which means the same coin can have different basis in different places and a low-basis lot cannot be parked elsewhere to sell a high-basis lot first. Software that still pools across wallets produces wrong returns.
No. Universal pooling ended for dispositions on or after January 1, 2025. Basis is tracked and identified per wallet or account.
Source: Treas. Reg. 1.1012-1(j)
Last reviewed September 18, 2026. Tax rules change; confirm current law before acting.
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