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Digital Assets

Our Managing Partner has advised companies building on blockchain technology since 2011. Today the firm serves bitcoin miners, protocol developers, foundations, token funds, and companies that hold crypto on the balance sheet.

Focus areas

What we work on

  • Token issuance and contributor compensation

    Tax treatment of token generation events, grants to employees and contributors, vesting schedules, and 83(b) elections.

  • Foundations and offshore structures

    Cayman foundation companies and other offshore vehicles, US presence planning, and PFIC exposure for US holders.

  • Fair value accounting and the provision

    Deferred tax effects of ASU 2023-08, valuation allowances on unrealized losses, and corporate AMT elections for large groups.

  • Mining and staking

    Income recognition, cost recovery on mining equipment, and state tax on hosting and power arrangements.

  • Token-to-equity restructurings

    Moving value from tokens into equity, with the holder-level and entity-level tax analysis that requires.

  • Reporting and basis

    Lot-level basis tracking and reconciliation to broker reporting on Form 1099-DA.

Bring us the hard question.

Tell us what you're working on. We'll tell you whether we can help, who would do the work, and what it would take.

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