IRS of the United States: Qualified trusts participating in PoS staking do not lose tax benefits

On October 6, the U.S. IRS released Revenue Procedure 2026-20, updating and replacing Revenue Procedure 2025-31 published in November 2025, clarifying that eligible investment trusts and grantor trusts can participate in PoS staking while retaining tax benefits.

The IRS defines compliant staking as "property preservation activities," allowing trusts to remain on the passive side and retain their status as investment trusts and grantor trusts (IRC Sections 671 to 677). This safe harbor includes 14 requirements, including shares listed on national exchanges, holding only a single digital asset, assets held by qualified custodians, liquidity policies approved by the SEC, and not hoarding staking rewards. This guidance applies to tax years ending on or after November 10, 2025.