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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.
How we help
Our practices, applied to Digital Assets
Tax Advisory
Provision, planning, and digital asset tax analysis for holders, issuers, and miners.
ExploreTransactions & Restructuring
Token-to-equity restructurings, acquisitions, and exchange offers.
ExploreFractional Finance Leadership
Head of Tax and treasury leadership for companies holding digital assets.
Explore
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.