01Counsel
Counsel of record
Tax counsel · Estate counsel · Trust attorneys · Bankruptcy & QSBS specialists · Jurisdiction-specific counsel
Liquidity & tax optimization for concentrated wealth
Plan yourexit.
Unlock liquidity from a concentrated position — public stock, a private company, or crypto. Reduce or defer the tax. A coordinated path from unrealized gains to working capital — modeled before you commit, monitored after you sign.
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The protocolSame protocol.
Same protocol.
Every client.
The discipline is fixed. The strategy is bespoke.
01
Position analysis
Cost basis reconstructed at the lot and transaction level — brokerage and RSU/option lots, private-company shares, and on-chain assets (DeFi, staking, and liquidity-pool activity all attributed).
02
Liquidity & tax paths
Every tool modeled against your lifecycle, jurisdiction, liquidity needs, and goals. The output is a comparison, not a recommendation.
03
Partner coordination
Counsel, lenders, fund partners, custodians, and administrators lined up before you commit. We project-manage the rollout.
04
Continuous oversight
Year-round basis tracking, LTV monitoring, election timing, and regulatory changes. Adjustments before they become amendments.
The benchCoordinated,
Coordinated,
not introduced.
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02Capital
Capital partners
Securities-based & crypto-native lenders · QOF sponsors · PPLI carriers · Investment banks & brokers
03Operations
Custody & administration
Securities & digital-asset custodians · Trust companies · Fund administrators · Qualified intermediaries
04Advisory
CPAs & financial advisors
Tax preparers · Financial advisors & RIAs · Existing-advisor coordination · Family-office liaison
05Compliance
Reporting & compliance
Tax-reporting platforms (brokerage & crypto) · Regulatory monitoring · Document & filing automation
Partner relationships are confirmed before any engagement is scoped. We do not name partners publicly until they have agreed to that representation.
The instruments
Tools for every position.
01 / Foundation
QSBS Verification
Reviews whether your equity qualifies for the IRC §1202 exclusion — up to $10M or 10x basis of federal capital gains eliminated per issuer.
CodeIRC §1202Benefit$10M exclusion
02 / Foundation
Donor-Advised Fund
Immediate tax deduction at full fair market value for donated appreciated assets — stock, fund interests, or crypto. No capital gains on the contribution, with flexible grant timing.
PathCharitable givingBenefitFMV deduction
03 / Lite
Qualified Opportunity Fund
Opportunity Zone deferral with permanent gain exclusion after 10+ years. Now permanent law under OBBBA 2025 — no sunset risk.
Code§1400Z-2PathDeferral + exclusion
04 / Lite
Charitable Remainder Unitrust
Sell appreciated assets inside the trust with no capital gains. Receive an income stream for life or term, plus a current charitable deduction.
PathIncome + deductionForCharitable intent
05 / Lite
Staking / Mining LLC
For validators, delegated stakers, and miners — an LLC wrapper with retirement-plan eligibility and pass-through optimization.
Code§162ForActive income
06 / Standard
Institutional PPLI
Permanent shelter that compounds tax-free — holding public equities, fund interests, or digital assets — with cash access via policy loans.
CodeIRC §7702LiquidityPolicy loans
07 / Standard
IDGT + Installment Sale
Sell an appreciated position — concentrated stock, private shares, or crypto — to a grantor trust for a note. Liquidity from note payments at AFR rates; future appreciation outside your estate.
Code§671–§679LiquidityNote payments
08 / Standard
Asset-Backed Lending
Liquidity from your position without selling. LTV-aware credit lines against concentrated stock, fund interests, or crypto — coordinated with institutional and crypto-native lenders, structured to avoid recognition events.
PathBorrow, don't sellForActive liquidity
09 / Premium
Multi-Trust QSBS Stacking
Multiply the $10M §1202 exclusion across family trusts — potentially sheltering $50M+ for a family of five through separate per-issuer caps.
CodeIRC §1202PathFamily stacking
10 / Premium
Rolling GRATs
Overlapping 2-year GRATs that systematically capture single-stock or crypto volatility. Each cycle resets on remainder gains for continuous wealth transfer.
PathWealth transferForVolatile assets
11 / Specialty
Wyoming DAO LLC
Governance and limited liability for on-chain entities. Formal LLC wrapper with legal standing for partners and counsel.
CodeWY §17-31ForDAOs & on-chain
12 / Specialty
Basis Ladder
Systematically stage exits across calendar boundaries and state-residency windows for controlled gain realization.
PathBasis optimizationForStaged exits
13 / Premium
Exchange Fund
Diversify a concentrated single-stock position without selling. Contribute shares into a pooled partnership and receive a diversified interest — no taxable event at contribution.
CodeIRC §721ForSingle-stock concentration
14 / Standard
Variable Prepaid Forward
Monetize a concentrated stock position for upfront cash while deferring the sale and retaining defined upside. A contractual forward, not a sale.
PathMonetize + deferForConcentrated stock
15 / Standard
§1045 QSBS Rollover
Sold QSBS held over six months? Roll the proceeds into new qualified small-business stock within 60 days and defer the gain — a bridge when the 5-year §1202 hold was not met.
CodeIRC §1045ForFounders & early investors
16 / Lite
Staged-Sale Plan (10b5-1)
A pre-arranged, rules-based schedule to sell concentrated or restricted stock — with an affirmative-defense trading plan and tax-lot sequencing layered on top.
RuleSEC 10b5-1ForInsiders & RSU holders
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The orchestrationModeled by AI.
Modeled by AI.
Executed by people.
Integration-first. The strategy engine stays deterministic — AI sits in the experience and coordination layers.
01
Strategy Discovery
A conversation that surfaces which strategies apply.
02
Plain-language Queries
"What would I save?" — engine answers, AI explains.
03
Document Drafting
Trust documents drafted for professional review.
04
Educational Guide
Adaptive explanations grounded in IRS publications.
05
Professional Matching
Matched to counsel by jurisdiction and specialization.
06
Continuous Monitoring
IRS rulings and your milestones, year-round.
“We orchestrate. The strategy engine stays deterministic — AI sits in the experience and coordination layers.”
How we workOne stop
One stop
shop.
Whether you need one tool or ten, we coordinate the full stack — counsel, capital, custody, and compliance — under one roof.
A — Strategy
The full toolkit.
Multi-tool engagement coordinated across counsel, lenders, fund partners, and custodians — built for both liquidity and tax outcomes.
Liquidity + tax paths modeled in parallelMulti-partner coordinationYear-round monitoring
Start strategy →B — Single Product
One tool, scoped.
When you already know what you need: a credit line, residency, single trust, custody alignment.
One tool, scoped to your situationSingle partner handoffFaster path to engagement
Pick a tool →Begin your intake.
Unlock liquidity from public stock, private equity, or crypto. Reduce or defer the tax. A coordinated path from unrealized to working capital.