While I am not a lawyer or tax accountant - I think it’s important to note that basically none of the reputable tax firms have made any statement on this. It is getting hyped by a bunch of cryptard crypto tax influencers to try sell you their kit.

The most reputable summary I’ve found is from RSM (link below). They frame it as an OPTIONAL action that one might take if they believe they can gin up some tax efficiencies for themselves out of it.

Otherwise it sounds like you’re just subject to FIFO on one hand (not unreasonable) and then (counterintuitively to the former thing) each “wallet”needs to have cost basis going forward (which is absurd).

They don’t know how to define a “wallet” and it is not clearly defined. To me the simplest way to think of then, in the absence of clarity, is tracking cost basis at the exchange level. Though even this will be difficult for many of us in a retroactive sense.

So going forward, I take this “regulation” if it is actually to be a real thing, to favor the following actions:

1. Keep it simple, use FIFO

2. Don’t mix bitcoin from different centralized exchanges (to contain the cost basis at the exchange level)

3. Don’t sell if you can help it.