About the Course
Introduction
This CLE/CPE course will provide tax and estate planning attorneys an in-depth analysis of challenges for cryptocurrency investors and the impact of recent IRS guidance for trusts engaged in digital assets. The panel will discuss the impact of Rev. Proc. 2025-31, asset protection, and investment management, as well as explore effective transaction structures and planning techniques to manage issues related to owning and investing in cryptocurrency.
Description
Cryptocurrency is considered personal property in the eyes of the IRS. These crypto assets will be part of an individual's estate, forcing estate planning and business counsel to consider various factors in planning for transfer and management of crypto assets.
For estate planning purposes, cryptocurrency is taxed similarly to real estate or stock. A sale or exchange can lead to capital gains or losses that must be reported on tax returns. Estate planning and tax advisers must consider this tax treatment when documenting gifts, utilizing trusts, and structuring transactions. Unique planning factors apply to cryptocurrencies that counsel must consider, such as the rules regarding the custody, security, and accessibility of digital assets; the Uniform Prudent Investor Act; and complex tax regulations.
In addition, the IRS issued Rev. Proc. 2025-31 providing guidance and safe harbors for investment and grantor trusts relating to digital assets without hindering status as trusts for federal income tax purposes.
Listen as our panel discusses the impact of crypto assets on estate planning and investment management that may arise, as well as offers essential techniques for the effective protection and administration of these types of assets.
Presented By
Mr. Dimon concentrates his practice on a wide variety of domestic and international tax matters, including both tax planning and tax controversy. He has worked with clients from equally varied backgrounds, including cutting-edge startups and large Fortune 100 companies.
Mr. McElroy advises clients, including early-stage startups, unicorns, and Fortune 100 multinationals on a wide array of domestic and international tax planning and tax controversy matters. He has particular expertise advising clients on tax matters related to blockchain and cryptocurrency ecosystems. Mr. McElroy has advised numerous clients on tax issues relating to token generation events, private token sales, NFTs, decentralized autonomous organizations (DAOs), and centralized and decentralized cryptocurrency structures. His clients in this space include protocol development teams, founders, investment platforms, cryptocurrency exchanges, and individual investors. Mr. McElroy also has experience representing clients in tax controversies. He has represented large multinational companies in advance pricing agreements, tax arbitrations, administrative proceedings against the IRS, in U.S. District Court, and in the U.S. Tax Court. Mr. McElroy has also represented taxpayers in controversies relating to the taxation of cryptocurrency.
Ms. Searing plans and prepares tax-efficient wills and trusts; advises on entity formations; and helps clients use gifts, sales, and other wealth-transfer strategies.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Tuesday, February 3, 2026
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. IRS Rev. Proc. 2025-31
II. IRS enforcement for cryptocurrency assets
III. Estate planning issues particular to cryptocurrency
IV. Asset protection for cryptocurrency
V. Hedge fund regulation and management for cryptocurrency
VI. Structuring investments to manage crypto assets
The panel will review these and other key issues:
- IRS Rev. Proc. 2025-31 and guidance for certain trusts
- Addressing estate planning issues for cryptocurrency
- Effective asset protection techniques for crypto assets; use of domestic and international trusts
- Best practices and key considerations to ensure effective management
- Tools for establishing pooled cryptocurrency investments
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