Since we're speculating...
Contemplate a sort of ICO where the developers hold X% of the tokens back for themselves. Once the ICO is over, I wonder what the basis of said tokens would be--zero? The price they sold at? Would it be considered income? (I would assume so, somehow, or it would be a very strange tax loophole.)
Good point, and I expect another complication is if the developers are acting through a legal entity (employees) or as individuals. Who gets the tokens in the end.
Some nonrecognition rules apply to stock (as opposed to the more broad "securities"), which makes it even more tricky.