1. So you want to do an ICO
Disclaimer The number of token offerings through ICOs or otherwise that have crossed my desk in the last 12 months has exploded. Many of those transactions have been put together with such speed that corporate structure and tax treatment are an afterthought with expensive consequences. Even now, most of the focus seems to be on the securities law treatment of Tokens. The following is a brief outline of some issues that are worth considering -- primarily in order to avoid adverse tax issues for founders, issuers and investors. Following posts will discuss different structures mentioned below in greater detail. Before we get to actual structures, however, it's important to understand what kinds of adverse things can happen to you. Many people think that selling Tokens should be taxed the same way as a stock sale is taxed -- but there is a specific Internal Revenue Code section that provides stock sales are tax free -- and it doesn't apply to Token sales. TAXATION OF TO