I had the same question also, but when the GBTC trust sells bitcoin to cover their expenses, Fidelity shows these expenses on my 1099-B (even if I have not sold anything). These expenses are reported to the IRS with box D checked. Thus I thought it is safer to say yes, since the IRS already has the expense data that was passed though to me. They should give more guidance on how to answer this question regarding trusts/etfs.
