SECTION 5. SCOPE

This revenue procedure applies to an arrangement formed as a trust under applicable State law that: (i) would be treated for Federal income tax purposes as a trust that qualifies as an investment trust under § 301.7701-4(c), and as a grantor trust, if the trust agreement did not authorize staking and the trust’s digital assets were not staked; and (ii) with respect to a trust in existence prior to the date on which its trust agreement first authorizes staking and related activities in a manner that satisfies each of the requirements of section 6.02 hereof, qualified as an investment trust under § 301.7701-4(c), and as a grantor trust, immediately before that date.