On November 10, 2025, the U.S. Treasury Department and Internal Revenue Service (IRS) issued Revenue Procedure 2025-31, providing a safe harbor for crypto ETFs to stake proof-of-stake (PoS) assets like Ethereum (ETH) and Solana (SOL) without jeopardizing the grantor trust tax structure, per. Treasury Secretary Scott Bessent tweeted, “The U.S. Treasury and IRS have issued new guidance giving crypto exchange-traded products (ETPs) a clear path to stake digital assets and share staking rewards with their retail investors. This move increases investor benefits, boosts innovation, and keeps America the global leader in digital finance.”
Revenue Procedure 2025-31 offers a tax-compliant “safe harbor” framework for crypto ETFs and trusts to stake proof-of-stake (PoS) assets such as Ethereum and Solana, while preserving their favorable tax treatment as grantor trusts and investment trusts, per , , , , , , , . Published on November 10, 2025, the procedure, Revenue Procedure 2025-31, went into effect immediately, per . This removes a major tax hurdle, allowing ETPs to stake holdings via qualified custodians like BitGo and Hex Trust, per . The safe harbor requires ETFs to hold a single digital asset, stake through unrelated third-party providers at arm’s length terms, and maintain 85% liquidity for redemptions.
Revenue Procedure 2025-31 creates a safe harbor for crypto ETFs to stake proof-of-stake (PoS) assets and distribute rewards directly to shareholders, per , , . Staking, a process where PoS networks like Ethereum (ETH ETF) and Solana (SOL ETF) lock assets to validate transactions and earn rewards, was previously a tax risk for trusts, per . The IRS and Treasury guidance ensures ETFs remain grantor trusts, avoiding entity-level taxation, per . Issuers must disclose staking activity and risks like slashing (validator penalties), with 85% liquidity for redempts and staking through arm’s length third-party providers, per . Circle’s USDC issuer role in facilitating this is crucial, per . Chainlink’s role in RWA development, including USDC and ETF data feeds, per , ties this to broader ETH and altcoin trends, per . The SEC’s non-security stance for most crypto further supports this, but staking’s tax status as ordinary income to investors (not trust-level) is the key unlock.
Ethereum (ETH ETF) and Solana (SOL ETF) prices have shown mixed reactions, with ETH holding $4,200 support and Solana at $184.50, per . BlackRock’s IBIT and ETH staking efforts, per , , indicate a swift response from ETF issuers. Analysts estimate 3–5% annual yields for Ethereum ETFs and 5–7% for Solana-based products, per . Grayscale and Fidelity are expected to amend ETH ETF prospectuses within nine months (by August 10, 2026), per , . The IRS’s Revenue Procedure 2025-31 clarifies tax treatment, taxing rewards as ordinary income to investors upon receipt of control, per . Solana’s liquid staking participation hit 12.2%, up 16.8% QoQ, with 64.8% of SOL’s circulating supply staked at $60B, per . The delay in Solana ETF approvals until October 16, 2025, has weakened SOL’s momentum, per . Layer Brett’s ETH L2 presale, with $0.0044 entry and 7,500% APY staking, adds competitive pressure, per . XRP ($2.29) and Solana ($184.50) prices remain stable, per CoinMarketCap, but the delay dampens XRP’s short-term momentum, per . XRP’s $128.6B market cap and $5.9B 24-hour volume rank it fourth, but ETF uncertainty limits institutional inflows, per . XRP’s $128.6B market cap and $5.9B 24-hour volume rank it fourth, but ETF uncertainty limits institutional inflows.
