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Crypto Cost Basis: FIFO, HIFO, and Specific ID

On this page
  1. In this guide
  2. FIFO, HIFO, and specific identification compared
  3. What specific identification requires after 2025
  4. Wallet-by-wallet and account-by-account basis
  5. Self-transfers, network fees, and lot continuity
  6. A defensible lot-selection workflow
  7. Related Bugaboo guides
  8. Frequently asked questions
  9. Sources reviewed
  10. Discuss your crypto lot records
  11. More from the Blog

Crypto tax records

By Jamie Waters

FIFO is the fallback when you cannot adequately identify the digital-asset units sold. HIFO is not a separate IRS method. It is a specific-identification strategy that requires timely, adequate identification and supporting records under the rules that apply to the transaction.

Cost-basis identification guidance updated November 3, 2026 | 11-minute read

Plain-English definition

A cost-basis method answers one question: Which acquisition lot did you dispose of? The answer affects basis, holding period, and gain or loss. It does not change what you actually received from the sale.

If you bought the same token at several prices, a sale must be matched to one or more acquisition lots. That match is easy to overlook because tax software can produce a polished report even when the source data is incomplete.

The right choice is not always the one that produces the smallest gain today. Holding period, available losses, future income, state tax, and the quality of your records can all change the answer.

Organized cryptocurrency tax lots moving into a wallet-based filing system
Lot selection must be supported by records for the wallet or account involved.

FIFO, HIFO, and specific identification compared

ApproachWhat it doesWhat it requiresMain risk
FIFOUses the earliest acquired units in that wallet or account first.Complete acquisition and transfer records.Old low-basis lots may create a larger gain.
HIFOSelects the highest-basis available units first.Adequate specific identification made on time.Software may label a report HIFO without proving the required identification.
Specific identificationSelects particular units based on supported identifiers.Timely identification plus supporting records; broker instructions or qualifying temporary relief may apply.A later reconstruction may not satisfy the identification rule.

FIFO is a fallback, not automatically a mistake

FIFO can produce long-term gains when the oldest lots have been held for more than one year. It may also produce a loss when the earliest lots have a high basis. You need the actual lot history before deciding whether FIFO helps or hurts.

HIFO is selection logic

HIFO is shorthand for selecting the highest-basis lots. The IRS rules focus on whether the disposed units were adequately identified, not on a software dropdown named HIFO.

That distinction matters. Choosing HIFO after the year ends does not automatically create a valid contemporaneous identification.

What specific identification requires after 2025

The general rule for broker-held digital assets requires identification to the broker by the transaction’s date and time, using accepted identifiers. However, IRS Notice 2026-20 extends temporary relief through December 31, 2026.

For qualifying broker-held transactions during the relief period, taxpayers can identify particular units in their own books and records by the transaction’s date and time, or record a sufficiently specific standing order before the transaction. If adequate identification is not made, FIFO applies within the account.

Important timing point

IRS Notice 2026-20 extends the relief first provided by Notice 2025-7 through December 31, 2026. It does not cover unhosted wallets or remove timely recordkeeping requirements. Taxpayer lot records may differ from broker-reported basis; reconcile those differences before filing. Check current guidance before relying on relief after 2026.

For an unhosted wallet, adequate records still matter. If you do not make a supported identification, the IRS FAQ default is FIFO within that wallet, regardless of when units were transferred into it.

Wallet-by-wallet and account-by-account basis

The universal or multi-wallet approach ended for digital assets held on January 1, 2025. Basis is now tracked separately for each wallet or account. Rev. Proc. 2024-28 provided a safe harbor for allocating previously unattached basis into those wallet-level pools if its conditions were met.

Separate wallets and exchange accounts retaining their own cryptocurrency basis records
Each wallet or account keeps its own lot history. A self-transfer carries the asset record rather than creating a universal pool.

A broker may report gross proceeds on Form 1099-DA without reporting basis for every transaction. Proceeds alone do not establish your gain. Your ledger still needs acquisition dates, basis, transfers, fees, and the units disposed of.

Self-transfers, network fees, and lot continuity

Moving your own asset between wallets you control is generally not a sale. The original basis and holding period travel with the asset, so the transfer record must connect the sending lot to the receiving wallet.

A network fee paid in cryptocurrency can be a separate disposition of the fee units. Do not delete fee transactions just because the principal transfer is not taxable.

If ownership of the destination wallet is unknown, treat it as an unresolved item. A blockchain address shows movement, but it does not prove who controlled the destination.

A defensible lot-selection workflow

  1. Reconcile the inventory first. Confirm every acquisition, disposal, income item, fee, and self-transfer.
  2. Separate wallets and accounts. Do not optimize one universal pool.
  3. Compare after-tax outcomes. Review basis and holding period, not only the largest available basis.
  4. Make the identification on time. Follow the applicable broker procedure or satisfy the temporary relief’s records and timing requirements.
  5. Keep evidence. Save broker confirmations, transaction IDs, acquisition records, and the calculation used.
  6. Review the final tax forms. Reconcile Form 1099-DA information to your transaction ledger and Form 8949 schedule.

Tax software can help with the calculations, but it cannot repair missing ownership evidence or create a timely instruction after the fact. Before relying on a report, test a few disposals all the way back to their source records.

Affiliate disclosure: Some resource links are affiliate links. Bugaboo may receive compensation if you buy through them, at no added cost to you. That does not change the review standard. See the full disclosures.

Koinly

Useful for consolidating exchange, wallet, and blockchain activity before reviewing lot assignments.

Review Koinly

CoinLedger

Another reporting option worth testing against your actual wallet and exchange records.

Review CoinLedger

Related Bugaboo guides

Frequently asked questions

Is HIFO an IRS-approved crypto cost-basis method?

HIFO is best understood as a specific-identification strategy. It is supportable only when the selected units are adequately identified and documented under the applicable rules.

What happens if I cannot identify the crypto units sold?

FIFO generally applies within the wallet or account involved. Complete transfer records are still needed to establish the basis and holding period of those units.

Can I choose HIFO after the sale?

Generally, no. A later software selection cannot create a timely identification. Under Notice 2026-20, qualifying broker-held transactions through December 31, 2026 may use identification in the taxpayer’s books and records by the transaction’s date and time, or a sufficiently specific standing order recorded beforehand.

Can I combine all wallets into one cost-basis pool?

No. Beginning in 2025, digital-asset basis is tracked wallet by wallet and account by account rather than through a universal pool.

Does Form 1099-DA give me complete cost basis?

Not always. Reconcile the form to your ledger because reported proceeds may not include basis for every covered and noncovered transaction.

Sources reviewed

Sources for the cost-basis identification update on November 3, 2026: IRS digital-asset transaction FAQs, Rev. Proc. 2024-28, Notice 2025-7, Notice 2026-20, and the IRS digital-assets filing hub.

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Discuss your crypto lot records

Start with a free consultation so we can understand the wallets, records, and work needed. If a deeper written review is useful, we may recommend an optional $500 Crypto Tax Diagnostic afterward. Any reconstruction is scoped separately.

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