Tax Consequences of ETH Exchange for ICO Tokens

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.