The whole thing is so obviously nothing but a “group your wallets by when you got the coins so our tax chainalysis is really easy” scheme.
And they call it “safe harbor” to trick people into thinking they are getting a benefit, imo.
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So what happens when I extract the private keys from my two HD wallets and combine them into one using spectrum? And then break them up into 2 other wallets with a differing set? What constitutes a wallet when anyone can mix and match whenever they see fit?