SECTION 4. TEMPORARY RELIEF

.01 Scope . The temporary relief described in section 4.02 of this notice is available only with respect to units of a digital asset held in the custody of a broker that are sold, disposed of, or transferred during the relief period.

.02 Temporary Relief under § 1.1012- 1(j)(3)(ii). A taxpayer may make an adequate identification during the relief period of a taxpayer’s units of a digital asset to be sold, disposed of, or transferred from the taxpayer’s units held in the custody of a broker by: (1) 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, disposed of, or transferred by reference to any identifier, such as purchase date and time or the purchase price for the unit, that is sufficient to identify the basis and holding

Bulletin No. 2026–15 801 April 6, 2026

period of the units sold, disposed of, or transferred; or (2) Recording a standing order on the

taxpayer’s books and records, provided that the recorded standing order includes sufficient information to identify any digital asset units sold, disposed of, or transferred and is entered into the taxpayer’s books and records before the units covered by the order are sold, disposed of, or transferred. .03 Nonapplication of § 1.1012-1(j) (3)(ii). If a taxpayer makes an adequate identification under subsection 4.02 of this notice, the rule in § 1.1012-1(j)(3) (ii), which treats taxpayers whose broker offers only one method of making a specific identification as having made a standing order or instruction, does not apply during the relief period.

.04 Safe harbor under Rev. Proc. 2024- 28 . Taxpayers relying on the safe harbor under Rev. Proc. 2024-28 may rely on the temporary relief described in section 4.02 of this notice only after the applicable requirements of Rev. Proc. 2024-28 have been satisfied.

.05 Adequate Identification. If the taxpayer has made an adequate identification on its books and records of the digital asset units sold, disposed of or transferred during 2026 pursuant to sections 4.014.04 of this notice, for Federal income tax purposes the units sold, disposed of or transferred by the taxpayer are the ones identified in the taxpayer’s books and records regardless of whether the information reported by the broker to the taxpayer matches the taxpayer’s books and records. If the taxpayer has instead specified to its broker, no later than the date and time of the sale, disposition, or transfer, the particular units of the digital asset to be sold, disposed of, or transferred by reference to any identifier that the broker designates as sufficiently specific to allow it to determine the basis and holding period of those units (including by communicating a standing order to the broker), for Federal income tax purposes the units sold,

disposed of or transferred by the taxpayer are the ones specified by the taxpayer to the broker