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Examination of Returns and Claims for Refund, Credit or Abatement; Determination of Correct Tax Liability

IRS Revenue Procedure 2026-20 provides federal tax guidance for investment trusts holding digital assets and participating in blockchain staking. Intended for financial institutions, trust administrators, tax professionals, and compliance teams, it establishes a safe harbor allowing qualifying trusts to stake digital assets without losing their investment trust or grantor trust tax status.

The procedure explains eligibility requirements, custodial arrangements, staking rewards, liquidity management, and investor protections. Readers will learn how trusts can comply with federal tax rules while participating in proof-of-stake networks, including requirements for distributing staking rewards within 60 days after the end of each calendar quarter. It also clarifies previous IRS guidance and establishes a transition period for existing trusts.

Examination of Returns and Claims for Refund, Credit or Abatement; Determination of Correct Tax Liability
Format:
  • Policy Brief
Topics:
Website:Visit Publisher Website
Author(s):
  • Internal Revenue Service
Publisher:Department of the Treasury
Published:October 6, 2026
License:Public Domain
Tags:blockchaincryptocurrencyDigital Asset TaxationDigital AssetsInvestment Trusts
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