Jacob V. Phillips

Private Client Services Associate Jacob Phillips authored an article for Tax Notes titled "To the Moon, Then to Charity: Using Charitable Remainder Trusts and Cryptocurrency." Jacob explores how charitable remainder trusts may be useful tools for charitably minded bitcoin investors who have held on to bitcoin through price fluctuations and wish to deploy or diversify large cryptocurrency holdings.

Excerpts:

Satoshi Nakamoto, whoever they are, probably has a huge tax bill coming.

The pseudonymous inventor (or inventors, it may have been a collective) of bitcoin published the white paper on cryptocurrency in 2008, then made the world’s first-ever bitcoin transaction in January 2009. Almost immediately thereafter, Nakamoto vanished, but not before posting proof that they had somewhere north of 1 million bitcoins in their digital wallet. As of 2026, Nakamoto’s bitcoin wallet remains untouched and is worth approximately $85 billion, which would make Nakamoto (if they really are one person) one of the 25 or so wealthiest people on the planet.

Unfortunately for Nakamoto, selling any portion of bitcoin holdings would be a tall order because the tax basis on their bitcoin assets is likely zero or close to zero. After all, Nakamoto acquired their bitcoins around the same time that one early user traded 10,000 bitcoins (now worth more than $780 million) for two Papa John’s pizzas. So if Nakamoto were to sell, they would realize a taxable capital gain on essentially the entire value of their holdings.