v3.26.1
Significant Accounting Policies
6 Months Ended
Jun. 30, 2026
Accounting Policies [Abstract]  
Significant Accounting Policies

2. Significant Accounting Policies

The following is a summary of significant accounting policies consistently followed by the Trust in the preparation of its financial statements.

Basis of Presentation

The financial statements are expressed in U.S. dollars and have been prepared in accordance with accounting principles generally accepted in the U.S. (“GAAP”). The Trust is an investment company and follows the specialized accounting and reporting guidance in the Financial Accounting Standards Board (“FASB”) Accounting Standards Codification (“ASC") Topic 946, Financial Services—Investment Companies.

Use of Estimates

The preparation of the financial statements in accordance with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of these financial statements. Actual results could differ from those estimates.

Cash

Cash represents cash deposits held at financial institutions and Crypto Asset exchanges. Cash in a bank deposit account, at times, may exceed U.S. federally insured limits. The Trust has not experienced any losses in such accounts and does not believe it is exposed to any significant credit risk on such bank deposits.

Investments and Valuation

The Trust’s investments in Crypto Assets are stated at fair value. For a further discussion of the Trust’s calculations of valuation, please see “Calculation of NAV and NAV per Share” in the footnote below. Crypto Assets are generally valued using prices as reported on reputable and liquid exchanges and may utilize an average of bid and ask quotes using closing prices provided by such exchanges as of the date and time of determination ("Investment Valuation - Principal Market Net Asset Value (NAV)" below). Factors such as the recent stability of the exchange, current liquidity of the exchange, and recent price activity of an exchange will be considered in the determination of which exchanges to utilize. The time used is 4:00 pm ET which corresponds to 20:00 UTC during Daylight Saving Time and 21:00 UTC during non-Daylight Saving Time. The Sponsor’s Valuation Policy provides a listing of preferred exchanges. While some Crypto Assets are valued based on prices reported in the public markets, other Crypto Assets may be more thinly-traded or subject to irregular trading activity. Determinations on the value of certain Crypto Assets, and how to value such assets as to which limited prices or quotations are available, are based on the Sponsor’s recommendations or instructions.

 

Crypto Asset transactions are recorded on the trade date. Realized gains and losses from Crypto Asset transactions are determined using the identified cost method. Any change in net unrealized gain or loss is reported in the statement of operations. Commissions and other trading fees are reflected as an adjustment to cost or proceeds at the time of the transaction.

 

The Trust intermittently receives Airdrops of new Crypto Assets. The use of Airdrops is generally to promote the launch and use of new Crypto Assets by providing a small amount of the new Crypto Assets to the private wallets or exchange accounts of holders of existing related Crypto Assets. Airdropped Crypto Assets can have substantially different Blockchain technology that has no relation to any existing Crypto Asset, and many Airdrops may be without value. The Trust will only record receipt of airdropped Crypto Assets if, when received, the airdropped Crypto Assets have value. Crypto Assets received from Airdrops have no cost basis and the Trust recognizes other income equal to the fair value of the new Crypto Asset received. There were no Airdrops recognized or unrecognized during the six-month period ended June 30, 2026 and the year ended December 31, 2025.

 

Investment Valuation - Principal Market Net Asset Value (“NAV”)

 

To determine which market is the Trust's principal market (or in the absence of a principal market, the most advantageous market) for purposes of calculating the Trust's net asset value in accordance with U.S. GAAP ("Principal Market NAV" and "Principal Market NAV per Share"), the Trust follows ASC Topic 820-10, Fair Value Measurement, which outlines the application of fair value accounting. ASC 820-10 determines fair value to be the price that would be received for Crypto Assets in a current sale, which assumes an orderly transaction between market participants on the measurement date. ASC 820-10 requires the Trust to assume that Crypto Assets are sold in its principal market to market participants or, in the absence of a principal market, the most advantageous market. Market participants are defined as buyers and sellers in the principal or most advantageous market that are independent, knowledgeable, and willing and able to transact.

In determining which of the eligible Digital Asset Markets is the Trust's principal market, the Trust reviews these criteria in the following order:

First, the Trust reviews a list of Digital Asset Markets that are U.S. accessible, have historically provided publicly available data, and are exchanges that Bitwise normally transacts on. Specifically, the Trust utilizes a third-party valuation vendor, Lukka, Inc., to identify publicly available, well-established and reputable crypto asset exchanges selected in its sole discretion.

Second, Lukka, Inc. sorts these Digital Asset Markets from high to low by market-based volume and level of activity of Crypto Assets traded on each Digital Asset Market. For the six months ended June 30, 2026, this sort was performed for Digital Asset Markets for the period mid-May through mid-June 2026.

 

Third, Lukka, Inc. then reviews pricing fluctuations and the degree of variances in price on each Digital Asset Market during the 60 minutes prior to 4:00 pm. EST for Crypto Assets to identify any material notable variances that may impact the volume or price information of a particular Digital Asset Market.

Fourth, Lukka, Inc. then selects a Digital Asset Market as its principal market based on the highest market-based volume level of activity and price stability in comparison to the other Digital Asset Markets on the list.

As of December 31, 2025, Lukka, Inc. included Binance, Bitfinex, Bitflyer, Bitstamp, Bullish, Bybit, Coinbase, Crypto.com, Gate.io, Gemini, HitBTC, Huobi, itBit, Kraken, KuCoin, LMAX, MEXC Global, OKX and Poloniex as its primary Exchange Markets in consideration.

 

The Trust determines its principal market (or in the absence of a principal market the most advantageous market) annually and conducts a quarterly analysis to determine (i) if there have been recent changes to each Digital Asset Market’s trading volume and level of activity in the trailing twelve months, (ii) if any Digital Asset Markets have developed that the Trust has access to, or (iii) if recent changes to each Digital Asset Market's price stability have occurred that would materially impact the selection of the principal market and necessitate a change in the Trust's determination of its principal market.

 

The following provides an overview of the Principal Market and the Principal Market Prices for Portfolio Crypto Assets that comprised the majority of the Trust’s assets for the six-month period ended June 30, 2026.

 

Asset

 

Principal Market Price

 

 

Principal
Market

Bitcoin (BTC)

 

$

58,716.53

 

 

Coinbase

Ethereum (ETH)

 

$

1,578.53

 

 

Crypto.com

XRP (XRP)

 

$

1.04

 

 

Coinbase

Solana (SOL)

 

$

73.62

 

 

Coinbase

Hyperliquid (HYPE)

 

$

65.47

 

 

Coinbase

Stellar Lumens (XLM)

 

$

0.19

 

 

Coinbase

Cardano (ADA)

 

$

0.14

 

 

Coinbase

Chainlink (LINK)

 

$

7.20

 

 

Coinbase

Litecoin (LTC)

 

$

41.80

 

 

Coinbase

Sui (SUI)

 

$

0.70

 

 

Coinbase

Various inputs are used to determine the fair value of assets and liabilities. Inputs may be based on independent market data (“observable inputs”) or they may be internally developed (“unobservable inputs”). These inputs are categorized into a disclosure hierarchy consisting of three broad levels for financial reporting purposes. The level of a value determined for an asset or liability within the fair value hierarchy is based on the lowest level of any input that is significant to the fair value measurement in its entirety. The three levels of the fair value hierarchy are as follows:

Level 1 – Valuations based on unadjusted quoted prices in active markets for identical assets or liabilities that the Trust has the ability to access.

Level 2 – Valuations based on quoted prices in markets that are not active or for which all significant inputs are observable, either directly or indirectly. These inputs may include (a) quoted prices for similar assets in active markets, (b) quoted prices for identical or similar assets in markets that are not active, (c) inputs other than quoted prices that are observable for the asset, or (d) inputs derived principally from or corroborated by observable market data by correlation or other means.

Level 3 – Valuations based on inputs that are unobservable and significant to the overall fair value measurement.

The cost basis of the investments in Crypto Assets recorded by the Trust for financial reporting purposes is the fair value of the Crypto Assets at the time of transfer. The cost basis recorded by the Trust may differ from proceeds collected by the Authorized Participant from the sale of the corresponding Shares to investors.

The following summarizes the Trust’s assets accounted for at fair value at June 30, 2026 (amounts in thousands):

 

 

Level 1

 

 

Level 2

 

 

Level 3

 

 

Total

 

Assets

 

 

 

 

 

 

 

 

 

 

 

 

Investments in Crypto Assets, at fair value

 

$

532,696

 

 

$

 

 

$

 

 

$

532,696

 

 

The following summarizes the Trust’s assets accounted for at fair value at December 31, 2025 (amounts in thousands):

 

 

Level 1

 

 

Level 2

 

 

Level 3

 

 

Total

 

Assets

 

 

 

 

 

 

 

 

 

 

 

 

Investments in Crypto Assets, at fair value

 

$

1,029,868

 

 

$

 

 

$

 

 

$

1,029,868

 

 

During the periods ended June 30, 2026 and December 31, 2025, there were no significant transfers into or out of any levels of the fair value hierarchy.

 

The following represents the changes in quantity of Crypto Assets and the respective fair values for the six-month period ended June 30, 2026:

 

 

Bitcoin (BTC)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

8,836.1188

 

 

$

773,549

 

Purchases

 

 

44.9106

 

 

 

2,707

 

Sales

 

 

(1,820.8624

)

 

 

(131,256

)

Net realized gain (loss) on investment

 

 

 

 

 

89,333

 

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(319,784

)

Balance at June 30, 2026

 

 

7,060.1670

 

 

$

414,549

 

 

 

 

 

 

 

 

 

Ethereum (ETH)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

53,393.7681

 

 

$

158,683

 

Purchases

 

 

270.3511

 

 

 

438

 

Sales

 

 

(11,163.5901

)

 

 

(24,270

)

Net realized gain (loss) on investment

 

 

 

 

 

17,032

 

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(84,795

)

Balance at June 30, 2026

 

 

42,500.5291

 

 

$

67,088

 

 

 

 

 

 

 

 

 

XRP (XRP)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

26,808,148.3800

 

 

$

48,981

 

Purchases

 

 

324,630.1329

 

 

 

398

 

Sales

 

 

(5,235,574.8753

)

 

 

(7,728

)

Net realized gain (loss) on investment

 

 

 

 

 

3,843

 

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(22,651

)

Balance at June 30, 2026

 

 

21,897,203.6376

 

 

$

22,843

 

 

 

 

 

 

 

 

 

Solana (SOL)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

248,993.3542

 

 

$

30,865

 

Purchases

 

 

3,979.9398

 

 

 

354

 

Sales

 

 

(48,787.7381

)

 

 

(4,412

)

Net realized gain (loss) on investment

 

 

 

 

 

921

 

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(12,696

)

Balance at June 30, 2026

 

 

204,185.5559

 

 

$

15,032

 

 

 

 

 

 

 

 

 

Hyperliquid (HYPE)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

 

 

$

 

Purchases

 

 

89,491.2733

 

 

 

5,884

 

Sales

 

 

(10,564.6790

)

 

 

(678

)

Net realized gain (loss) on investment

 

 

 

 

 

(17

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(22

)

Balance at June 30, 2026

 

 

78,926.5943

 

 

$

5,167

 

 

 

 

 

 

 

 

 

Stellar Lumens (XLM)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

 

 

$

 

Purchases

 

 

12,588,308.0031

 

 

 

2,847

 

Sales

 

 

(729,556.3826

)

 

 

(151

)

Net realized gain (loss) on investment

 

 

 

 

 

(15

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(477

)

Balance at June 30, 2026

 

 

11,858,751.6205

 

 

$

2,204

 

 

 

 

 

 

 

 

 

Cardano (ADA)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

16,225,913.9193

 

 

$

5,402

 

Purchases

 

 

83,667.1776

 

 

 

12

 

Sales

 

 

(3,160,403.4213

)

 

 

(857

)

Net realized gain (loss) on investment

 

 

 

 

 

(3,378

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

724

 

Balance at June 30, 2026

 

 

13,149,177.6756

 

 

$

1,903

 

 

 

 

 

 

 

 

 

Chainlink (LINK)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

313,437.5474

 

 

$

3,837

 

Purchases

 

 

1,615.7481

 

 

 

12

 

Sales

 

 

(61,049.7732

)

 

 

(578

)

Net realized gain (loss) on investment

 

 

 

 

 

71

 

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(1,513

)

Balance at June 30, 2026

 

 

254,003.5223

 

 

$

1,829

 

 

 

 

 

 

 

 

 

Litecoin (LTC)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

33,920.6399

 

 

$

2,598

 

Purchases

 

 

174.8584

 

 

 

8

 

Sales

 

 

(6,606.8899

)

 

 

(367

)

Net realized gain (loss) on investment

 

 

 

 

 

(480

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(610

)

Balance at June 30, 2026

 

 

27,488.6084

 

 

$

1,149

 

 

 

 

 

 

 

 

 

Sui (SUI)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

1,653,967.2590

 

 

$

2,308

 

Purchases

 

 

8,526.0832

 

 

 

6

 

Sales

 

 

(322,151.3405

)

 

 

(337

)

Net realized gain (loss) on investment

 

 

 

 

 

(984

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(61

)

Balance at June 30, 2026

 

 

1,340,342.0017

 

 

$

932

 

 

 

 

 

 

 

 

 

Avalanche (AVAX)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

190,139.0261

 

 

$

2,345

 

Purchases

 

 

 

 

 

 

Sales

 

 

(190,139.0261

)

 

 

(1,715

)

Net realized gain (loss) on investment

 

 

 

 

 

(2,349

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

1,719

 

Balance at June 30, 2026

 

 

 

 

$

 

 

 

 

 

 

 

 

 

Polkadot (DOT)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2026

 

 

729,577.6306

 

 

$

1,300

 

Purchases

 

 

 

 

 

 

Sales

 

 

(729,577.6306

)

 

 

(911

)

Net realized gain (loss) on investment

 

 

 

 

 

(9,870

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

9,481

 

Balance at June 30, 2026

 

 

 

 

$

 

 

 

 

 

 

 

 

 

As of June 30, 2026, Bitcoin represented 77.82% of the total Portfolio Crypto Assets held by the Trust, and Ethereum represented 12.59%, while the remaining 9.59% of the Portfolio Crypto Assets were composed of XRP, Solana, Hyperliquid, XLM, Cardano, Chainlink, Litecoin, and Sui.

 

Additions during the year primarily represent Crypto Assets purchased due to creations into the Trust and in-kind creations. Dispositions during the year represent Crypto Assets sold as a result of shareholder redemptions from the Trust and in-kind redemptions. In addition, Crypto Assets were sold to pay the Sponsor Fee of the Trust. For the six months ended June 30, 2026, the Trust recognized net realized gains of $94,107,222, which represent the net of cumulative realized gains of $111,389,482 and cumulative realized losses of $17,282,260.

 

The following represents the changes in quantity of Crypto Assets and the respective fair values for the year ended December 31, 2025:

 

 

Bitcoin (BTC)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

10,632.1413

 

 

$

992,968

 

Purchases

 

 

3.5303

 

 

 

328

 

Sales

 

 

(1,799.5528

)

 

 

(165,407

)

Net realized gain (loss) on investment

 

 

 

 

 

119,592

 

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(173,932

)

Balance at December 31, 2025

 

 

8,836.1188

 

 

$

773,549

 

 

 

 

 

 

 

 

 

Ethereum (ETH)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

65,011.3388

 

 

$

217,164

 

Purchases

 

 

570.5775

 

 

 

1,469

 

Sales

 

 

(12,188.1482

)

 

 

(36,229

)

Net realized gain (loss) on investment

 

 

 

 

 

23,651

 

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(47,372

)

Balance at December 31, 2025

 

 

53,393.7681

 

 

$

158,683

 

 

 

 

 

 

 

 

 

XRP (XRP)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

30,686,126.7901

 

 

$

64,340

 

Purchases

 

 

1,439,571.8875

 

 

 

3,136

 

Sales

 

 

(5,317,550.2976

)

 

 

(11,128

)

Net realized gain (loss) on investment

 

 

 

 

 

4,962

 

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(12,329

)

Balance at December 31, 2025

 

 

26,808,148.3800

 

 

$

48,981

 

 

 

 

 

 

 

 

 

Solana (SOL)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

256,477.2246

 

 

$

49,677

 

Purchases

 

 

36,637.5790

 

 

 

5,491

 

Sales

 

 

(44,121.4494

)

 

 

(6,154

)

Net realized gain (loss) on investment

 

 

 

 

 

(693

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(17,456

)

Balance at December 31, 2025

 

 

248,993.3542

 

 

$

30,865

 

 

 

 

 

 

 

 

 

Cardano (ADA)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

19,192,702.8414

 

 

$

16,262

 

Purchases

 

 

411,637.1580

 

 

 

242

 

Sales

 

 

(3,378,426.0801

)

 

 

(1,558

)

Net realized gain (loss) on investment

 

 

 

 

 

(2,970

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(6,574

)

Balance at December 31, 2025

 

 

16,225,913.9193

 

 

$

5,402

 

 

 

 

 

 

 

 

 

Chainlink (LINK)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

342,097.2780

 

 

$

6,828

 

Purchases

 

 

30,202.6854

 

 

 

402

 

Sales

 

 

(58,862.4160

)

 

 

(814

)

Net realized gain (loss) on investment

 

 

 

 

 

(33

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(2,546

)

Balance at December 31, 2025

 

 

313,437.5474

 

 

$

3,837

 

 

 

 

 

 

 

 

 

Avalanche (AVAX)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

220,206.9730

 

 

$

7,886

 

Purchases

 

 

4,421.5228

 

 

 

76

 

Sales

 

 

(34,489.4697

)

 

 

(499

)

Net realized gain (loss) on investment

 

 

 

 

 

(561

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(4,557

)

Balance at December 31, 2025

 

 

190,139.0261

 

 

$

2,345

 

 

 

 

 

 

 

 

 

Sui (SUI)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

 

 

$

 

Purchases

 

 

1,985,863.2240

 

 

 

7,705

 

Sales

 

 

(331,895.9650

)

 

 

(601

)

Net realized gain (loss) on investment

 

 

 

 

 

(759

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(4,037

)

Balance at December 31, 2025

 

 

1,653,967.2590

 

 

$

2,308

 

 

 

 

 

 

 

 

 

Litecoin (LTC)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

 

 

$

 

Purchases

 

 

40,872.6900

 

 

 

5,239

 

Sales

 

 

(6,952.0501

)

 

 

(566

)

Net realized gain (loss) on investment

 

 

 

 

 

(325

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(1,750

)

Balance at December 31, 2025

 

 

33,920.6399

 

 

$

2,598

 

 

 

 

 

 

 

 

 

Polkadot (DOT)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

816,152.3229

 

 

$

5,434

 

Purchases

 

 

49,191.1633

 

 

 

110

 

Sales

 

 

(135,765.8556

)

 

 

(323

)

Net realized gain (loss) on investment

 

 

 

 

 

(2,288

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(1,633

)

Balance at December 31, 2025

 

 

729,577.6306

 

 

$

1,300

 

 

 

 

 

 

 

 

 

Bitcoin Cash (BCH)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

10,611.6785

 

 

$

4,625

 

Purchases

 

 

 

 

 

 

Sales

 

 

(10,611.6785

)

 

 

(4,462

)

Net realized gain (loss) on investment

 

 

 

 

 

9

 

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

(172

)

Balance at December 31, 2025

 

 

 

 

$

 

 

 

 

 

 

 

 

 

Uniswap (UNI)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

 

 

$

 

Purchases

 

 

320,996.9789

 

 

 

4,351

 

Sales

 

 

(320,996.9789

)

 

 

(3,751

)

Net realized gain (loss) on investment

 

 

 

 

 

(600

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

 

Balance at December 31, 2025

 

 

 

 

$

 

 

 

 

 

 

 

 

 

NEAR Protocol (NEAR)

 

 

Units

 

 

Fair Value

 

Balance at January 1, 2025

 

 

680,674.8151

 

 

$

3,330

 

Purchases

 

 

 

 

 

 

Sales

 

 

(680,674.8151

)

 

 

(3,326

)

Net realized gain (loss) on investment

 

 

 

 

 

(1,425

)

Net change in unrealized appreciation (depreciation) on investment

 

 

 

 

 

1,421

 

Balance at December 31, 2025

 

 

 

 

$

 

 

As of December 31, 2025, Bitcoin represented 75.11% of the total Portfolio Crypto Assets held by the Trust, and Ethereum represented 15.41%, while the remaining 9.48% of the Portfolio Crypto Assets were comprised of XRP, Solana, Cardano, Chainlink, Litecoin, Avalanche, Sui, and Polkadot.

 

 

Calculation of NAV and NAV Per Share

 

On each business day, as soon as practicable after 4:00 p.m. ET, the NAV of the Trust is obtained by subtracting all accrued fees and other liabilities of the Trust from the fair value of the Crypto Assets and other assets held by the Trust. The Bank of New York Mellon (the “Administrator”) computes the NAV Per Share by dividing the NAV of the Trust by the number of Shares outstanding on the date the computation is made.

 

Income Taxes

 

The Trust is classified as a partnership for U.S. federal income tax purposes. As a result, the Trust itself is not subject to U.S. federal income tax. Instead, the Trust’s income and expenses “flow through” to the Shareholders, and the Administrator reports the Trust’s income, gains, losses, and deductions to the Internal Revenue Service on that basis. The Sponsor has analyzed applicable tax laws and regulations and their application to the Trust, and does not believe that there are any uncertain tax positions that require recognition of a tax liability as of June 30, 2026.

 

The Trust is required to determine whether its tax positions are more likely than not to be sustained on examination by the applicable taxing authority, based on the technical merits of the position. Tax positions not deemed to meet a more likely than not threshold would be recorded as a tax expense in the current year. As of June 30, 2026 and December 31, 2025, the Trust has determined that no provision for income taxes is required and no liability for unrecognized tax benefits has been recorded. The Trust does not expect that its assessment related to unrecognized tax benefits will materially change over the next 12 months. However, the Trust’s conclusions may be subject to review and adjustment at a later date based on factors including, but not limited to, the nexus of income among various tax jurisdictions; compliance with U.S. federal, U.S. state, and tax laws of jurisdictions in which the Trust operates and changes in the administrative practices and precedents of the relevant authorities. The Trust is required to analyze all open tax years. Open tax years are those years that are open for examination by the relevant income taxing authority. As of June 30, 2026, all tax years since inception remain open for examination. There were no examinations in progress at period end.

 

Organizational and Offering Costs

 

The costs of the Trust’s organization and the initial offering of the Shares are borne directly by the Sponsor. The Trust is not obligated to reimburse the Sponsor.