Revenue Procedure 2025-31: Fixed Investment Trust Staking

Revenue Procedure 2025-31 describes a safe harbor for trusts that otherwise qualify as investment trusts under § 301.7701-4(c) and grantor trusts to stake their digital assets without jeopardizing their tax status as investment trusts and grantor trusts for Federal income tax purposes. This revenue procedure also provides a limited time period for an existing trust to amend its governing instrument to adopt the requirements of the safe harbor.

Revenue Procedure 2025-31 will be in IRB: 2025-48, dated: 11/24/2025

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