Law Office of Andrew L. Gradman, APC

Education and Affiliations

• NYU SCHOOL OF LAW, LL.M. in Taxation, 2016.
• NYU STERN SCHOOL OF BUSINESS, Certificate in Law & Business.
• COLUMBIA LAW SCHOOL, J.D., 2011.
• STANFORD UNIVERSITY, B.A. (History), 2006.

State bar: California (2011); Nevada (2019).
Certified Tax Specialist, California Board of Legal Specialization
Co-chair of ethics subcommittee: ABA Section of Taxation, Committee on Standards of Tax Practice.

Publications

Articles about Opportunity Zones have asterisks**.

• Journal of Taxation of Investments
  • A Call for IRS Guidance on the Information Corporations Give Shareholders to Show That Stock Is QSBS.
• Tax Notes Federal
  
  • OBBBA’s new credit for contributions to Scholarship Granting Organizations:  The ship of state springs a leak. 7/31/2025
  • **How Forgiving Recapture Gain Turns QOZs into Tax Shelters. 11/25/19.
  • **Incremental OZ Reform Could Be a Step Backward. (letter to the editor) 5/9/22.
  • The IRS (or Congress) Should Clarify When Structured Installment Sales Will Be Respected. (letter to editor) 12/20/24.
• Tax Notes State
  • **Opportunity Zone Planning When Penalties are a Certainty. 7/11/22.
• ABA Tax Times
  • Miranda Stewart, Tax and Government in the 21st Century: Book Review and Interview with the Author. With Jonathan Grossberg. 09/25/23.
  • The Case For Letting Taxpayers Buy Ivermectin with Health Savings Accounts. 03/09/23.
• Bloomberg Insights
  (This publisher often makes my words incomprehensible. They should use this disclaimer: "This article may not reflect the opinion of the publisher or the author.")
  
  • IRS Can Fix Tax Trap for Unwary With Timely Qualified Appraisal. 11/9/23. With Matthew Rapaport and Sam Brady.
  • Anonymous Letter to IRS Lays Out Defense of Malta Pension Plans. 9/11/23.
  • Deferring Tax with IRC 453, Without Crossing the Line. 5/2/22.
  • **Using a Qualified Opportunity Fund to Invest in non-QOZ Property. 03/15/22.
  • Cannabis Taxpayers Find Flaws in New Section 471(c) Regs. With AB FinWright, LLP. 03/11/21
  • Hidden Tax Dangers in Cannabis Outsourcing Arrangements. With AB FinWright, LLP. 09/15/21
• Bloomberg Tax Journals
  • Negative Capital Freezes and Subchapter K. Real Estate Journal; Estate, Gifts, & Trusts Journal, 10/19/22.
  • The Installment Method: Misuses that Make Me Lose Sleep. Real Estate Journal, 05/18/22.
  • **What Good is OZ Reporting if We Don’t Agree on the Goals? Real Estate Journal, 03/16/22.
  • Family Offices Allow (Some) Taxpayers to Deduct Investment Related Expenses. Estates, Gift, and Trusts Journal, 03/12/20. With Alan S. Gassman et al.
• Leimberg Information Services, Inc.
  • Avoiding the Trustee's "Personal Liability" for Estate Taxes. Newsletter, 03/11/2025.
• California Tax Lawyer (Publication of the California Lawyers Association - Taxation Section)
  • **Personal Goodwill For New QO Funds, Business Goodwill For Old Ones: IRS May Cry “Whipsaw".  February 2022. 
• CEB Reporters
  • QSBS Letters: Best (and Worst) Practices. Business Law Reporter. March 2022.
  • Avoiding California Taxation: Considerations for Individuals Currently Domiciled in the State. Business Law Reporter. July 2021.
  • Trustee's Personal Liability for Estate Taxes. Estate Planning & California Probate Reporter. November 2021.
  • Real Estate Tax Tips During Coronavirus. Real Property Law Reporter. May 2020.
  • Coronavirus Legislation Contains Employment Tax Relief, and Mixed Messages. Business Law Reporter. July 2020.
  • California Taxation (Sep. 2020) Case Summary. 42 Cal. Bus. L. Rep. 2
• LA Daily Journal
  • If you squander this once-in-a-lifetime chance to make tax-free gifts, you're not a bad person. 11/02/21.
  • **QOZ projects have ‘up to’ 24 more months due to COVID-19. 03/19/20. With Michael Wiener.
  • **Treasury Releases Long-Awaited QOZ Regulations. 04/19/19. With Neda Barkhordar.
  • Should You Change Your Accounting Method? An Emerging Cannabis Loophole. With AB FinWright, LLP. 06/16/20
• Quoted in
  • Wall Street Journal, IRS Says Tax-Free Maltese Pensions Are Too Good to Be True. 12/21/21.
  • Bloomberg, Trump’s Flirtation With a Millionaire Tax Demonstrates Uncertainty Around Bill, 4/28/2025
• Your Tax Matters Partner blog
  • The Stuff That Dreams Are Made Of – The Rise And Fall Of Malta Pension Plans. 02/02/22.
• CEB (CA Continuing Education of the Bar) blog
  • **IRS Releases Generous Guidance for QOZs During Coronavirus Pandemic.
  • **Poking Holes in the Final QOZ Regulations. 01/30/20.
  • Limits on the Installment Method of Accounting for Gain. 10/15/20.
  • California Passes Partial Tax Conformity Bill, Raising More Questions. 10/17/19.
  • Split Roll Ballot Measure Could Scale Back Proposition 13. 10/01/20
  • Employment Tax Relief Under the Families First and CARES Acts. 05/06/20
    
    
• 420cpa.com blog
  • The Mechanics of the Cannabis Cultivation Tax in California. 07/24/20. With Abraham Finberg & Rachel Wright. 

• Unpublished 
  • Incentive under the CARES Act to Invest in Capital Intensive Businesses During 2020.
• Update author for publications by CEB (CA Continuing Education of the Bar):
  • Advising California Employers and Employees - chapter 7, “Tax Compliance”
  • Advising California Partnerships - chapter 3, “Tax Considerations on Formation of and Contributions to Partnership” 
  • Advising California Partnerships - chapter 14, “Taxation of Transfers and Terminations of Partnership Interests”
  • Advising California Partnerships - chapter 16, "Dissociation and Transfer of Partnership Interests"
  • Business Buy-Sell Agreements - chapter 3, “Corporate Buy-Sell Agreements”
  • Drafting California Irrevocable Trusts - chapter 14, “Grantor Retained Income Trusts (GRITs)"
  • Drafting California Irrevocable Trusts - chapter 15, “Grantor Retained Annuity Trusts (GRATs)”
  • Organizing Corporations in California - chapter 1, "Considerations Before Incorporation"
  • Organizing Corporations in California - chapter 2A, “Conversions and Mergers”
  • Trade Secrets Practice in California - chapter 15, "Taxation of Trade Secrets"
• Comments to proposed Treasury regulations
  • REG-116610-20, "Regulations Governing Practice Before the Internal Revenue Service": Submitted my own comment, and contributed to the comment by the American Bar Association
  • REG-109348-22, “Identification of Monetized Installment Sale Transactions as Listed Transactions”: comment
  • REG-120186-18, Investing in Qualified Opportunity Funds, comment and comment

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