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Technology & AI
Venture-backed software and AI companies make tax decisions early that are expensive to unwind later. We help founders and finance teams make them deliberately, from formation through exit.
Focus areas
What we work on
Formation and US presence
Entity choice, US subsidiaries for founders and companies based abroad, and managing where the business is taxable.
Equity compensation
Section 83 and 83(b) elections, founder and employee equity, and token-based incentives for crypto-adjacent products.
Research and development costs
Treatment of research and experimental expenditures under Sections 174 and 174A, including the split between domestic and foreign research, and the research credit.
Sales tax on software
Nexus and taxability reviews for SaaS and digital products, and remediation of historical exposure before a financing or sale.
Exit readiness
Sell-side tax diligence, QSBS eligibility analysis under Section 1202, and cleanup ahead of an acquisition.
IP location and transfer pricing
Where intellectual property sits, how it is licensed between affiliates, and transfer pricing that matches the structure.
How we help
Our practices, applied to Technology & AI
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.