Analysis (to the extent possible under limited authority) of potential tax consequences of exchange of appreciated Ethereum for ICO tokens in ICO.  Review of potential application of S. 351 in the context of SEC application of the Howey doctrine to utility-token ICOs.  Review of reporting requirements for 5%+ participants in ICO obtained with appreciated ETH and possible tacking of holding period and basis application for subsequent sales.

Pre-IPO advice and liaison to appropriate boutique advisory shops for non-US enterprise contemplating US listing.  International tax structuring advice on GILTI rules, interest allocation and optimal corporate structure for resulting Delaware HoldCo of non-US operational entities.

Review and restructuring of family ownership structure of multiple operating entities including formalizing handshake agreements from original startup phase and establishing inter-generational planning for the various enterprises.  Split of ownership between different operations to equalize out to prior agreement from differential titling.