Rev. Proc. 2026-20 Fixed Investment Trust Staking

IRS GuideWire

October 6, 2026

Issue Number: Rev. Proc. 2026-20

Inside This Issue

Revenue Procedure 2026-20 describes a safe harbor for trusts that otherwise qualify as investment trusts under § 301.7701-4(c) and as grantor trusts to stake their digital assets without jeopardizing their tax status as investment trusts and grantor trusts for Federal income tax purposes. This revenue procedure also provides a limited time period for an existing trust to conform its governing instrument (trust agreement) and procedures to the requirements of the safe harbor. This revenue procedure clarifies, modifies, and supersedes Rev. Proc. 2025-31, 2025-48 I.R.B. 743.

Revenue Procedure 2026-20 will be in IRB: 2026-43, dated:10/26/2026

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