Self-custody Bitcoin whales have been moving coins into ETFs (mostly BlackRock's IBIT).
In July 2025, the SEC approved a rule change that allows tax-free, in-kind transfers of self-custody Bitcoin to exchange-traded funds (ETFs).
With this change, large Bitcoin holders can exchange their coins for ETF shares without incurring tax liabilities.
Bloomberg reported that over $3 billion worth of Bitcoin has been converted into BlackRock ETF shares through in-kind transfers.
However, this is a one-way valve (coins → ETF shares = easy/tax-efficient; ETF shares → coins = hard/taxable).
In other words, you can't do the inverse.
You can't go to the Fink and give him your BTC receive address and say: "Exchange my ETF shares for sats and send here you dirty rat" because he'll tell you "Sell ETF and pay tax first you stupid slave".
This is not an accident. It's the control equilibrium: herd value into surveilled, controllable wrappers and keep exit into sovereign self-custody costly, taxable, and reputationally suspect.
More context on why self-custody Bitcoin whales are moving into ETFs:
https://controlplanecapital.com/p/why-self-custody-bitcoin-whales-are
More context on why Bitcoin treasuries will be forced to buy ETFs instead of spot BTC:
https://controlplanecapital.com/p/why-bitcoin-treasury-companies-will
The article on why the plebs won't be able to "ETF shares → coins" without tax is in the works.