Notice 2026-20 relief ends December 31. The part people are missing is what happens to lot identification on January 1.

Disclaimer: Not tax advice, educational purposes only. Consult your own tax professional.

We are are mod of r/CryptoTax and as a firm that primarily performs crypto reconciliation read Notice 2026-20 properly this week and there are two things in it that I have not seen discussed, both with a deadline attached.

JustinCPA wrote the best explanation of why your books and the exchange diverge, and why that divergence is permanent. Read that first, it is the better piece on the mechanism. This post is about the timing, which is where I think people are going to get caught.

1. The relief never let you choose your method at filing time

This is the one that surprised me. Section 4.02 says an adequate identification is made by:

Identifying, no later than the date and time of the sale, disposition, or transfer, on the taxpayer's books and records, the particular units to be sold

or by a standing order:

entered into the taxpayer's books and records before the units covered by the order are sold, disposed of, or transferred

So the relief removed the requirement to tell your broker. It did not remove the requirement to have identified the lots at or before the disposal. You cannot decide in April 2027 that your 2026 sales were LIFO.

Practically, if your tax software has had a cost basis method set the whole time, that likely functions as your standing order. What matters is that it was set before the trades and that you can show when.

If you have been trading through 2026 with no method configured and nothing recorded, the default in 1.1012-1(j)(3)(i) is FIFO, and that is already your position for those disposals.

2. What actually changes on January 1, 2027

Section 5 is explicit that you cannot rely on the books and records method for disposals made after the relief period ends.

So from January 1 you are back to the regulation: specify the units to your broker at or before the sale, or have a standing order with the broker. Do neither and FIFO applies.

Here is the part worth sitting with. The reason this relief exists at all is that brokers could not accept specific identifications. The notice says many custodial brokers:

are not currently ready to accept specific identifications (other than standing orders) from customers

and are only expected to finish building those systems during 2026.

Which means the question to answer before year end is not really about your records. It is: can each exchange you actually use accept a specific identification or a standing order yet? If it cannot, and the relief has expired, you are on FIFO there whether that suits you or not.

3. It does not cover self custody

Worth stating plainly, because a lot of people here are mostly on chain.

The relief applies only to units held in the custody of a broker. The notice says so directly. Units not in a broker's custody are governed by 1.1012-1(j)(1) and (2) instead, and nothing here changes that.

What I would do before December 31

1. Check what cost basis method your software has been using for 2026, and when it was set. Screenshot it. That is your evidence of a standing order.

2. Ask each exchange you use whether it can accept a specific identification or standing order for 2027, and set it if it can.

3. Import every wallet and exchange, including dead ones. A transfer that never got linked leaves a lot with zero basis, and that error propagates into every disposal after it.

4. Reconcile balances per account, not just transactions. If your software balance does not match the actual balance, you have missing data, and the transaction list will not tell you that.

5. Save a lot level snapshot as at December 31. That is the opening position you carry into 2027.

One correction while I am here: the "your books control" language is in Section 4.05 of the notice, not 3.05. Section 3 is just definitions. I have seen 3.05 quoted a few times and it is worth citing correctly if you are relying on it.

I may have misread something, and the guidance could move again. If you think I have it wrong, say so and I will correct it.

- AurumFSG (Crypto Tax Accounting Firm)