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Thanks @bobreedo, I think you are on to something. New entrants are currently buying in GBTC at a premium to underlying Bitcoin. Are you saying, if Bitcoin is transferred to settle the management fee (or sold for USD to settle the fee in USD), it seems like there could be a loss recognized; if the fair value of BTC is less than new entrants' price to acquire the equivalent portion of their stock which could be deemed their underlying BTC basis? Plus, do you think there would be a potential itemized deduction w/ 2% AGI haircut for the fair value of the management fee (prorata share)? And do we expect these would occur due to the trust rules, even if the price of the stock keeps going up (with basis adjusted for the person's final stock sale)?

These trust rules are complex, so I might not have it 100% correct from all angles; either way, at the end of the day, if folks on this platform are buying GBTC, I am expecting to see a flurry of posts when tax season comes around.