Audits are inevitable
The IRS treats high-net-worth digital asset portfolios with deep skepticism. We build structures anticipating an audit on day one.
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.
- 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 work.
Every engagement is composed against these commitments. They shape the agreements we draft, the protections we add, and the questions we ask before signing.
Entity architecture matters
Holding crypto in your own name is a liability. We use specific corporate wrappers to isolate risk and optimize tax treatment.
Valuation requires defense
When transferring illiquid tokens, the appraisal must be mathematically sound and legally defensible.
What we watch · 02
The considerations.
Where attention concentrates during the engagement — the structures, terms, and protections that decide whether the agreement holds when 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. No magic, no vapor — just enforceable documents and considered counsel.
- 01
Asset Profiling
We categorize your portfolio by tax treatment—differentiating long-term holds from active staking operations and governance tokens.
- 02
Entity Formation
We establish the domestic or offshore corporate vehicles necessary to hold the assets efficiently.
- 03
CPA Integration
We coordinate directly with your accountants to ensure the legal structure seamlessly supports the technical tax filings.
- 04
Audit Defense
If the IRS initiates an inquiry, we stand as a shield between the agency and your private records.
Where this connects · 02
Disciplines often used here.
This practice area sits inside one primary discipline and touches others. Each card describes the cross-discipline connection in concrete terms.
SCHEDULE A CONSULTATION
Review your tax posture.
Ensure your tokenized assets and staking operations are structured to withstand intense regulatory scrutiny.
Review your tax posture