Arjun Kowalski Venkatesan , PhD Computer Science, CFA

Arjun bridges the gap between the engineering teams building token protocols and the tax professionals who have to report the results. His clients are engineers, protocol designers, and founders at crypto-native companies where compensation arrives as a mix of USD salary, traditional stock options, and token grants with vesting schedules denominated in protocol tokens rather than shares. The IRS has yet to issue definitive guidance on most of these instruments, so his planning work lives in the space between Section 83 analogies and Rev. Rul. 2014-21.

The representative fact pattern is a restricted token unit grant with a four-year vest and a one-year cliff. A protocol engineer receives 400,000 tokens at grant, token price $0.08, target price at cliff unknown. If the tokens are treated as substantially vested at grant under 83(a), a timely 83(b) election locks in $32,000 of ordinary income and starts the capital-gains clock immediately, a good trade if the token appreciates materially. If the grant is structured as a contractual right to future tokens rather than a present transfer, 83(b) is unavailable and the income recognizes at each vesting date on the then-current price, which for a token that runs from $0.08 to $4.20 is a $1.65M ordinary-income event across the vest. The documentation differences that drive this outcome are usually not visible to the recipient.

He reviews content on token compensation, self-custody cost-basis, and the reporting framework around digital-asset wages.