Selling or rebalancing

Last checked 29 October 2026. This page describes how a written policy can handle sales. It does not suggest when to sell. If anything here conflicts with the linked source, the source wins.

A treasury policy should say, before anything happens, what can lead to a sale, who can propose one, who must approve it and how it is recorded. Decisions then follow the policy rather than the mood of the market. The triggers below are rules a board can choose to adopt, not forecasts. The policy side is the same in the UK and the US. The tax side differs, so it has a section for each country.

Sell triggers a policy can name

The sizing guide helps set the band, and the policy guide shows where these clauses sit.

Approvals and withdrawals

• Set approval levels by size: for example, larger sales need a board resolution, smaller ones two named officers. No single person should be able to sell or move funds.
• Keep a list of approved destinations: the company's account at each approved provider, set up in advance and verified. Use the provider's withdrawal allow list if it has one.
• Prepare each transaction as a partially signed transaction (PSBT), and have two keyholders each check the amount and destination on their own device screen before signing.
• For a new destination, send a small test first.
• Money from a sale should only return to a bank account in the company's name.

Source: Bitcoin BIPs: BIP 174: Partially Signed Bitcoin Transaction format (PSBT), Bitcoin BIPs: BIP 11: M of N standard transactions (multisig), Lockton (insurance broker): Cryptocurrency insurance: best practices for custodians.

See the 2 of 3 multisig page for how signing works, and buying as a company for the test transaction routine, which works the same way in reverse.

Record keeping

For each sale, keep:

• the trigger, the proposal and the approval, with the board minute or resolution;
• the date and time, amount, proceeds in pounds or dollars and how the value was found;
• the transaction ID of the move to the provider, and the provider's trade confirmation;
• fees, both network and provider;
• the updated cost records: the pool in the UK, or the basis of the units left in each wallet or account in the US.

Source: HMRC: CRYPTO40100: Conversion to sterling and accountancy, HMRC: CRYPTO41300: Corporation Tax on chargeable gains, allowable costs, IRS: Digital assets, IRS: Revenue Procedure 2024-28: allocating unused basis to wallets and accounts (PDF).

The UK tax link

Each sale is a disposal for Corporation Tax and gives a gain or loss against the pooled cost. If the company sells and buys bitcoin within a short period, the same day and ten day matching rules can change which costs are used, so the result may differ from a simple pool calculation. Rebalancing that both sells and buys in the same few days should be checked with your accountant. Providers also report customer transactions to HMRC under the Cryptoasset Reporting Framework.

Source: HMRC: CRYPTO41250: Corporation Tax on chargeable gains, what counts as a disposal, HMRC: CRYPTO41350: Corporation Tax on chargeable gains, pooling and the same day and ten day rules, HMRC: CRYPTO49000: Cryptoasset Reporting Framework.

The company tax page explains pooling with HMRC's example.

The US tax link

Each sale is a disposal that gives a capital gain or loss: the dollar proceeds less the basis of the units sold. Units are identified wallet by wallet or account by account, oldest first unless the company makes a valid specific identification at the time of sale. Choosing which units to sell can change the gain, so agree the method with your accountant before the first sale.

Source: IRS: Digital assets, IRS: Revenue Procedure 2024-28: allocating unused basis to wallets and accounts (PDF), IRS: Notice 2025-7: identifying digital asset units held by a broker (PDF).

A corporation can only use capital losses against capital gains. Unused losses are generally carried back 3 years and forward 5 years. A broker may send a Form 1099-DA, but corporations are generally exempt recipients, and the company must report every sale whether or not a form arrives.

Source: IRS: Publication 542, Corporations: 21% rate and capital losses, IRS: Understanding your Form 1099-DA, IRS: Instructions for Form 1099-DA (2026): covered securities, basis reporting and exempt recipients.

The wash sale rule: not settled

The wash sale rule, section 1091 of the Internal Revenue Code, stops a loss being claimed when stock or securities are sold and substantially identical ones are bought within 30 days before or after the sale. The Joint Committee on Taxation said in September 2026 that digital assets are not expressly within section 1091, and that the IRS has not issued regulations or guidance on whether the rule may apply.

A bill, the Digital Asset Tax Certainty Act (H.R.10357), would change this. It was introduced on 14 September 2026 and ordered reported by the Ways and Means Committee two days later. It is not law. As amended in committee, it would apply to disposals after 14 September 2026 if enacted, which means a rule passed later could reach back to sales already made.

Source: Joint Committee on Taxation: Description of H.R. 10357, the Digital Asset Tax Certainty Act, September 2026 (PDF), Joint Committee on Taxation: JCX-50-26: Description of the amendment in the nature of a substitute to H.R. 10357 (PDF), Congress.gov: H.R.10357, Digital Asset Tax Certainty Act: all actions.

The company tax page covers basis, rates and Form 1099-DA.

Read next

• Policy guide: write the rules before you need them.
• Board meeting checklist: questions for each review.
• Accountant's corner: year end
• Sizing guide: set the band.
• Peer-to-peer settlement: fraud, escrow and payment reversals.

Sources

Primary sources only. Each link was checked on 29 October 2026. Rules change, so confirm the current version with your adviser.

1. Bitcoin BIPsBIP 174: Partially Signed Bitcoin Transaction format (PSBT)
2. Bitcoin BIPsBIP 11: M of N standard transactions (multisig)
3. Lockton (insurance broker)Cryptocurrency insurance: best practices for custodians
4. HMRCCRYPTO40100: Conversion to sterling and accountancy
5. HMRCCRYPTO41300: Corporation Tax on chargeable gains, allowable costs
6. IRSDigital assets
7. IRSRevenue Procedure 2024-28: allocating unused basis to wallets and accounts (PDF)
8. HMRCCRYPTO41250: Corporation Tax on chargeable gains, what counts as a disposal
9. HMRCCRYPTO41350: Corporation Tax on chargeable gains, pooling and the same day and ten day rules
10. HMRCCRYPTO49000: Cryptoasset Reporting Framework
11. IRSNotice 2025-7: identifying digital asset units held by a broker (PDF)
12. IRSPublication 542, Corporations: 21% rate and capital losses
13. IRSUnderstanding your Form 1099-DA
14. IRSInstructions for Form 1099-DA (2026): covered securities, basis reporting and exempt recipients
15. Joint Committee on TaxationDescription of H.R. 10357, the Digital Asset Tax Certainty Act, September 2026 (PDF)
16. Joint Committee on TaxationJCX-50-26: Description of the amendment in the nature of a substitute to H.R. 10357 (PDF)
17. Congress.govH.R.10357, Digital Asset Tax Certainty Act: all actions