Tax Advisory
Tax planning and technical analysis for companies whose assets, entities, and transactions sit outside the standard playbook. We answer the question, document the position, and support it through audit.
Capabilities
What we do
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Income tax provision (ASC 740)
Preparation or review of quarterly and annual provisions, uncertain tax position analysis, valuation allowance assessments, and responses to auditor inquiries. Includes the deferred tax effects of fair value accounting for crypto assets under ASU 2023-08 and the expanded income tax disclosures under ASU 2023-09.
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Federal and international planning
Entity classification, PFIC and CFC exposure, QEF and other elections, related-party transfer pricing, and cross-border structures involving the Cayman Islands and other offshore jurisdictions.
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Equity and token compensation
Section 83 treatment of stock and tokens issued for services, 83(b) elections, vesting design, and payroll withholding and reporting.
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State and local tax
Sales and use, franchise, and property tax analysis, nexus reviews, and state incentive programs, including the Texas data center sales tax exemption and local property tax abatements.
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Digital asset tax
Realization, character, and basis analysis for mining, staking, treasury, and token issuance activity, and reconciliation of broker reporting on Form 1099-DA to your own lot records.
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Tax controversy support
Technical tax analysis for outside counsel in privileged engagements, including Kovel arrangements, and support responding to IRS and state inquiries.
When clients call us
Situations we see most often
- You hold crypto assets and now account for them at fair value under ASU 2023-08.
- Your auditors are asking tax questions your team can't answer before the filing deadline.
- You are forming or restructuring entities across the US and offshore jurisdictions.
- You are granting stock or tokens to employees, contributors, or advisors.
- You are building or expanding facilities in a state with incentive programs.
- Counsel needs privileged tax analysis for a dispute or a filing review.
Industries
Where we apply it
Talk to us about tax advisory.
Tell us the question, the deadline, and who else is involved. We'll tell you how we would approach it.