The IRS just changed the game for crypto taxes
IRS Notice 2026-20 extends temporary relief through December 31, 2026, letting you use your own cost basis method (FIFO, LIFO, HIFO, or specific identification) regardless of what your exchange uses internally.
That's a big deal. Your exchange defaults to FIFO. You might save thousands using HIFO. And the IRS says that's fine through 2026.
What does this actually mean?
Section 3.05 of the notice says you can make your own lot identifications on your own books and records, "regardless of whether the information reported by the broker to the taxpayer matches the taxpayer identification."
In plain English: your records are the source of truth, even when the exchange disagrees.
A simple example
Say you bought ETH throughout 2026:
January: 1 ETH @ $2,000
March: 1 ETH @ $2,500
May: 1 ETH @ $3,000
Then you sell 1 ETH in July for $3,200.
Your exchange (FIFO): Sells the January lot. Gain = $1,200.
Your records (HIFO): Sells the May lot. Gain = $200.
Same sale. $1,000 difference in taxable gains. The IRS says your HIFO is the correct answer for 2026.
Why this matters beyond 2026
Once you use a different method than your exchange, your remaining lot pools diverge. The exchange thinks it's holding different lots than your books show. This fork is permanent. You can't switch back without filing an inconsistent return.
When 1099-DAs arrive in 2027 with the exchange's (incorrect) FIFO basis, you'll need to use adjustment codes on Form 8949 to reconcile the difference.
This isn't something to fear. It's how the system is designed to work. Your books control. The 1099-DA becomes a starting point you adjust from, not a target you have to hit.
What you should do right now
<strong class="text-[#e4e1ed]">Track your actual lot history</strong> across all exchanges and wallets using crypto tax software.
<strong class="text-[#e4e1ed]">Choose the method that saves you the most</strong> (HIFO usually minimizes taxes).
<strong class="text-[#e4e1ed]">Keep lot-level records organized.</strong> You'll need them when 1099-DAs arrive.
<strong class="text-[#e4e1ed]">Don't panic about matching the exchange.</strong> The IRS explicitly said you don't have to.
How CryptoTaxPilot helps
CryptoTaxPilot automatically compares FIFO and HIFO for your portfolio, showing you exactly how much each method saves. Your records in CryptoTaxPilot become your source of truth, generating Form 8949 from your actual lot history.
When 1099-DAs arrive in 2027, we'll show you exactly where the exchange disagrees with your records and generate the adjustment codes automatically.