Rev. Proc. 2020-34, page 990.

This revenue procedure grants temporary relief to trusts which are, or have tenants who are, experiencing financial hardship as a result of COVID-19, to allow them to make certain modifications to their mortgage loans and their lease

agreements, and to accept additional cash contributions without jeopardizing their tax status as grantor trusts. The revenue procedure indicates that a cash contribution from one or more new trust interest holders to acquire a trust interest or a non-pro rata cash contribution from one or more current trust interest holders must be treated as a purchase and sale under § 1001 of a portion of each non-contributing (or lesser contributing) trust interest holder’s proportionate interest in the trust’s assets.