Starting Jan 1, 2025, the per-wallet cost basis goes into effect. The time to do the Safe Harbor thing, if you’re going to, I think is right now. But you may practically have until your first spend of 2025.

I’m really not sure. The Bitcoin.tax guidance is what I’m going off of.

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So we have to report all our transactions in non KYC wallets?

I don’t recall reading anything about reporting transactions per se

Ok, thanks.

What I mean is, the transaction data (addresses etc.) are out of scope.

Technically speaking, any spend is a taxable event, and the IRS expects you to report that you disposed of coin, at the current market price, and according to your acquired basis.

IN ADDITION, the network fee you pay to miners counts as “disposition” as though you sold the coin for dollars and then spent those dollars on the transaction. EVEN IF you’re just transferring from your own wallet to another wallet you control.

It’s bonkers that they expect this level of tracking and reporting, but that’s the letter of the law as I understand it.

That's impossible

Correct