PRACTICE · CRYPTO & DIGITAL ASSETS

Crypto Tax & Corporate Structuring

High-net-worth positions in decentralized finance generate highly scrutinized, incredibly complex tax events. Staking rewards, airdrops, and illiquid token portfolios demand rigorous, defensible valuation methodologies that can withstand aggressive IRS audits. We work intimately alongside CPAs to build corporate entities and tax structures that protect capital, harvest losses strategically, and ensure your enterprise remains insulated from shifting regulatory classifications.

Begin the matterReview the steps
Discipline
Crypto & Digital Assets
Engagement
Per matter or retainer
Counsel
Christopher Moye
CRYPTO & DIGITAL ASSETS
Audits are inevitable
The IRS treats high-net-worth digital asset portfolios with deep skepticism.
Principles · 01

How we draft the matter.

Every engagement is composed against these commitments. They shape the protections we add, the questions we ask, and the document that leaves the file.

§ 01

Audits are inevitable

The IRS treats high-net-worth digital asset portfolios with deep skepticism. We build structures anticipating an audit on day one.

§ 02

Entity architecture matters

Holding crypto in your own name is a liability. We use specific corporate wrappers to isolate risk and optimize tax treatment.

§ 03

Valuation requires defense

When transferring illiquid tokens, the appraisal must be mathematically sound and legally defensible.

What we watch · 02

What can break the matter.

These are the terms, structures, and practical risks that usually decide whether the work holds when the file is tested.

FOUNDERWHALE

Illiquid Token Valuation

Developing defensible, historically sound appraisal methodologies for low-liquidity NFTs and governance tokens to satisfy IRS scrutiny during estate transfers and charitable giving.

PATRIARCHFAMILY OFFICE

Tax-Loss Harvesting & Charitable Trusts

Utilizing sophisticated instruments, including Charitable Remainder Trusts, to offset massive capital gains from early crypto investments while preserving philanthropic intent.

INNOVATORDEGEN

Staking & Airdrop Structuring

Designing the corporate entity structures required to manage the aggressive tax realization events associated with staking operations, liquidity pools, and protocol airdrops.

The work · 03

Four steps. One engagement.

Each step is concrete; each step has a deliverable. The scope is defined, the matter moves, and the file closes.

  1. 01

    Asset Profiling

    We categorize your portfolio by tax treatment—differentiating long-term holds from active staking operations and governance tokens.

  2. 02

    Entity Formation

    We establish the domestic or offshore corporate vehicles necessary to hold the assets efficiently.

  3. 03

    CPA Integration

    We coordinate directly with your accountants to ensure the legal structure seamlessly supports the technical tax filings.

  4. 04

    Audit Defense

    If the IRS initiates an inquiry, we stand as a shield between the agency and your private records.

SCHEDULE A CONSULTATION

Review your tax posture.

Ensure your tokenized assets and staking operations are structured to withstand intense regulatory scrutiny.

Send us your matter