U.S. Treasury issues Revenue Procedure 2025-31 allowing grantor-trust crypto ETFs to stake and distribute rewards

first published 2025-11-10T21:38:10Z

The U.S. Treasury and IRS issued guidance establishing a safe harbor that permits investment trusts and exchange-traded products to stake single-asset holdings on permissionless proof-of-stake networks and share staking rewards with investors. To qualify, trusts must hold only one token type from a PoS network, follow specified liquidity protocols, perform no other functions besides holding/staking/redeeming, and use a custodian plus an independent staking provider. Officials praised the move as clearing legal and tax uncertainty and said it is expected to boost institutional participation and mainstream adoption; staking yields cited range from about 1.8%–7% annually.

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Treasury and IRS issued a safe-harbor guidance that explicitly allows trusts and ETPs to stake single-asset PoS holdings and distribute staking rewards, requires single-token holdings, liquidity protocols, no other functions, and reliance on a custodian plus independent staking provider; officials said the move clears legal and tax uncertainty and is expected to boost institutional participation and mainstream adoption; staking yields cited at ~1.8%–7% annually.

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