The eligibility limit is narrow and specific, and it is the single most important fact to get right about this method. Treasury Regulation 1.1012-1(e) restricts the average basis method to stock in a regulated investment company, the technical category that reaches mutual funds, and to shares acquired after December 31, 2010, in connection with a dividend reinvestment plan, where the shares are left in an account maintained by a custodian or agent for that purpose. Ordinary corporate stock bought through a brokerage account, even stock the investor happens to be reinvesting dividends into manually, does not qualify. The rule is written this way because a mutual fund shareholder's account typically reflects many small automatic purchases over time, made through periodic investments and reinvested distributions, which would be genuinely impractical to track lot by lot the way an investor buying individual stock shares in occasional, discrete purchases can.
The calculation itself blends every purchase into one number. The average basis of the shares in the account is computed by adding the total cost, including reinvested distributions, of all the shares held, and dividing that total by the total number of shares. Every share in the account then carries that same average per-share basis, regardless of which specific purchase it actually came from. When shares are sold, they are treated as coming from the earliest-acquired shares still in the account for holding-period purposes, but every share, old or new, carries the identical averaged basis figure for computing the gain or loss itself.
An election is generally binding, which is unlike specific identification's sale-by-sale flexibility. Once a shareholder elects the average basis method for a covered security, the regulation generally requires that election to continue governing those shares going forward, and switching to a different method for that position typically requires the consent of the IRS. This is a meaningfully different posture from specific identification, which an investor can use or not use, lot by lot, at each individual sale. Choosing average basis is closer to a standing policy for the account than a decision made fresh each time shares are sold.
The trade-off is convenience against control, and it runs in the opposite direction from specific identification. Because every share carries the same averaged basis, an investor using this method cannot target the highest-basis shares to minimize a gain, or a specific long-held lot to secure favorable treatment, the way an investor using specific identification can. What average basis offers instead is simplicity: an investor who has made dozens or hundreds of small reinvestment purchases over years does not have to track each one individually to compute a sale's basis.
The method has a history worth a brief mention, since older material can reference it. Before rules effective for shares acquired on or after January 1, 2012 were finalized, mutual fund shareholders could in some cases use a "double-category" version of average basis, dividing shares into short-term and long-term groups and averaging separately within each. That transition method has been phased out for shares acquired under the current regime, and current guidance governs a single blended average rather than the older two-category approach.