The IRS published Revenue Procedure 2026-20, superseding the initial version from November 2025, clarifying how eligible investment trusts and grantor trusts can participate in proof-of-stake blockchain networks while maintaining favorable tax treatment. The guidance requires trusts to meet 14 detailed conditions, including having interests listed on a national exchange, holding a single type of digital asset, using qualified custodians, and implementing SEC-approved liquidity policies. The guidance applies to tax years ending on or after November 10, 2025, with trusts given a nine-month transition window to amend their governing instruments. The clearest beneficiaries are issuers of exchange-traded products holding single proof-of-stake assets, though multi-token baskets and trusts unable to meet all conditions remain outside the safe harbor’s protection.
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