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Rev. Proc. 2025-31

SECTION 9. DRAFTING

Internal Revenue Bulletin 2025-48 · 2026-10-03 edition · updated 2026-10-04 · United States

INFORMATION

The principal author of this revenue procedure is Andrew B. Christopherson of the Office of Associate Chief Counsel (Passthroughs, Trusts, and Estates). For further information, contact Andrew B. Christopherson at (202) 317-3889 (not a toll-free number).

held by the trust. The trust’s staking rewards, net of trust expenses, are, in proportion to the trust interest holders’ relative interests in the trust, either distributed in-kind to trust interest holders or sold for cash and the proceeds distributed to trust interest holders, in each case on a periodic basis that is no less frequently than quarterly. The trust treats all staking rewards consistently.

.03 Amendment . A trust may amend its trust agreement to authorize staking at any time during the nine-month period beginning on November 10, 2025 and such an amendment will not prevent a trust from being treated as a trust that qualifies as an investment trust under § 301.7701-4(c) or as a grantor trust if the requirements set forth in section 6.02 of this revenue procedure are satisfied.

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▸Contents — Internal Revenue Bulletin 2025-48
Internal Revenue Bulletin 2025-48

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