About my practice
I advise clients on income tax planning.
I counsel individuals, businesses, and their lawyers/CPAs at key moments--entity formation, retention of key employees, sale of business property, and exit from business. I draft and review contracts, LLC operating agreements, buy/sell agreements, real estate transaction documents, etc. to ensure qualification for tax benefits. I often prepare research memos and detailed written opinions to provide reassurance to CPAs and investors.
I also have extensive experience with transfer taxation (gift, estate, GST); property taxation; and other miscellaneous state and federal taxes.
- NYU SCHOOL OF LAW, LL.M. in Taxation, May 2015-May 2016.
- NYU STERN SCHOOL OF BUSINESS, Advanced Professional Certificate in Law & Business.
- COLUMBIA LAW SCHOOL, J.D., 2011. Articles Editor, Science and Technology Law Review.
- STANFORD UNIVERSITY, B.A. (History), 2006.
State bar: California (2011); Nevada (2019).
LA Lawyer's Philharmonic (cello)
Volunteer, Bet Tzedek Low-Income Taxpayer Clinic
- Qualified Opportunity Zones:
- How Forgiving Recapture Gain Turns QOZs into Tax Shelters. Tax Notes. Front page article 11/25/19.
- IRS Releases Generous Guidance for QOZs During Coronavirus Pandemic. CEB (accepted for publication).
- QOZ projects have ‘up to’ 24 more months due to COVID-19. LA Daily Journal 03/19/20. With Michael Wiener.
- Poking Holes in the Final QOZ Regulations. CEB website 01/30/20.
- Treasury Releases Long-Awaited QOZ Regulations. LA Daily Journal 04/19/19. With Neda Barkhordar.
- Statewide presentation to CEB (recording, handout).
- Statewide presentation to CalCPA (recording).
- Should You Change Your Accounting Method? An Emerging Cannabis Loophole. With Abraham Finberg and Rachel Wright. LA Daily Journal (accepted for publication, date TBA).
- Incentive under the CARES Act to Invest in Capital Intensive Businesses During 2020
- Real Estate Tax Tips During Coronavirus. CEB Real Property Law Reporter. Accepted for May 2020.
- Coronavirus Legislation Contains Employment Tax Relief, and Mixed Messages. CEB Business Law Reporter. Accepted for July 2020.
- Both CEB articles were adapted into a statewide presentation to CalCPA (recording).
- Partnership taxation
- CEB Update Author, "Tax Considerations on Formation of and Contributions to Partnership";
- CEB Update Author, "Taxation of Transfers and Termination of Partnership Interests";
- Intellectual Property
- CEB Update Author, “Taxation of Trade Secrets”.
- California Passes Partial Tax Conformity Bill, Raising More Questions. CEB website 10/17/19.
- Split Roll Ballot Measure Could Scale Back Proposition 13. CEB website (accepted for publication, date TBD).
- Family Offices:
- Family Offices Allow (Some) Taxpayers to Deduct Investment Related Expenses. Bloomberg Tax: Estates, Gift, and Trusts Journal 03/12/20. With Alan S. Gassman, John N. Beck, and Christopher J. Denicolo.
Areas of experience
No income tax topic is too obscure. My areas of experience include:
- Subchapters C and S (corporations): e.g.
- corporate mergers, tax-free reorganizations, and liquidations;
- professional goodwill
- Subchapter K (partnerships): e.g.
- drafting partnership allocations & distributions;
- structure employee equity compensation
- Subchapter J (trusts): e.g.
- grantor vs. complex trusts.
- Subchapter N (international): e.g.,
- tax planning for non-US persons
- tax planning for US expatriots
- assist CPAs with foreign accounts compliance
- Subchapters O (gain/loss), P (capital gain): e.g.,
- reduce tax on sale of corporation using Qualified Small Business Stock
- advise on use of cryptocurrencies in business transactions
- recharacterize sales to maximize capital gain treatment and expedite basis recovery.
- 1031 exchanges.
- Subchapter Z: Recognized expert on Qualified Opportunity Zones.
- Subchapters A (tax credits), B (computation of TI), (D (deferred comp), E (accounting methods), F (exempt orgs), G (PHCs and AET), I (depletion of natural resources), e.g.:
- 263A Unicap rules
- Taxation of tax-exempt and deferred-compensation structures
- Section 38 business credits, including R&D; LIHTC; NMTC; and IRC 46 Investment credits (rehab, energy)
- Taxation of sophisticated financial products, e.g.: private placement life insurance contracts; derivatives; capital vs. profits interests. Experienced with taxation of annuities (private and commercial) and life insurance (including split dollar)
- Taxation of farmers and ranchers
- Taxation of cannabis
- Executive compensation, including 409A
- CA Revenue & Tax Code: e.g.,
- allocation & apportionment.
- assist clients emigrating to Nevada to reduce income taxes.