The flip side is what I am optimizing for. I am interested in making it harder for them to check anything by their own rules. And all I can tell them is that I don't know, because I don't. If they want to try to figure it out, they can go right ahead, but at the end of the day, they won't know either, and I have no intent or motivation to help them.

Since they will mostly believe whatever I say, it is to my benefit to say only what can be obviously confirmed. That is, at the time the sats sold went on the exchange (which is likely reporting to them), they were valued at X, and when exchanged for fiat, they were valued at Y. This is my best try at complying, although everyone knows it is not 100%. Any valuation prior to those sats being on the exchange is clouded in assumption.

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Discussion

Here are my main concerns.

If you use another KYC place to store from purchase to sell, it's easy to trace from Exchange A to B and back again. With no other inflows cost basis is safely assumed at purchase price on Exchange A.

If flows between A and B don't match, you've either sold somewhere else and are not declaring it, you bought/obtained somewhere else and are not declaring it. You are keeping a stack somewhere that is neither A or B. At that point you'll most likely be asked to provide evidence of the third option in order to discard the other two, or you'll likely face tax evasion charges. Now, in order to prove the third option AND disprove the other two, you'll need to have the mismatching amount somewhere else no more, no less.

You may think, if they can't prove what you have or don't somewhere else, they can't prove there's a mismatch. While true, I think you might be overestimating the presumption of innocence of your country. Once "sufficient proof" has been brought up, the burden of proof will be shifted from them to you and not providing proof of those reserves will be equated to tax evasion and money laundering.

That's why it's called parallel accounting and not multiple-times-intersecting accounting. If you don't want to pay taxes on your non-KYC, your KYC and your non-KYC should never mingle. And if you are going to do that, then what's the point on moving stuff between KYC services/wallets?

That's my two sats, anyway

I think that it is not that easy to trace the transfers when done via lightning between exchanges. If we were talking on-chain transfers, I completely agree with you.

If both exchanges are KYC, you should assume both are sending the information to your tax agency. So neither of the exchanges can trace it, but the outside observer receiving the information from both sides can definitely see it.