
Law Office of Andrew L. Gradman
![]() | I am brought in by lawyers and CPAs to help them identify, mitigate, and (where all else fails) allocate the tax risks and benefits in their clients' business and personal transactions. andrew@gradmantax.com |
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.
CA Tax Specialist exam, passed 3/22 (admission pending approval)
LA Lawyer's Philharmonic (cello)
Volunteer, Bet Tzedek Low-Income Taxpayer Clinic
Publications
All errors are mine, except for the typographical errors; these were added by the editors of the respective publications.
Articles about Opportunity Zones have asterisks**.
- Tax Notes
- **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.
- California Tax Lawyer (Publication of the California Lawyers Association - Taxation Section)
- **QOZ Planning When Penalties are a Certainty. Accepted for publication (2022).
- **Personal Goodwill For New QO Funds, Business Goodwill For Old Ones: IRS May Cry “Whipsaw". February 2022.
- Bloomberg Insights
- Deferring Tax with IRC 453, Without Crossing the Line. 5/2/22.
- **Using a Qualified Opportunity Fund to Invest in non-QOZ Property. 03/15/2022.
- Cannabis Taxpayers Find Flaws in New Section 471(c) Regs. With AB FinWright, LLP. 03/11/2021
- Hidden Tax Dangers in Cannabis Outsourcing Arrangements. With AB FinWright, LLP. 09/15/2021
- Bloomberg Tax Journals
- The Installment Method: Misuses that Make Me Lose Sleep. Real Estate Journal (accepted for publication).
- **What Good is OZ Reporting if We Don’t Agree on the Goals? Real Estate Journal, 03/16/2022.
- Family Offices Allow (Some) Taxpayers to Deduct Investment Related Expenses. Estates, Gift, and Trusts Journal, 03/12/20. With Alan S. Gassman et al.
- 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. 11/02/2021.
- **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. 06/16/2020
- Quoted in
- Wall Street Journal, IRS Says Tax-Free Maltese Pensions Are Too Good to Be True. 12/21/2021
- Your Tax Matters Partner blog
- 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. 10/15/2020.
- California Passes Partial Tax Conformity Bill, Raising More Questions. 10/17/19.
- Split Roll Ballot Measure Could Scale Back Proposition 13. 10/01/2020
- Employment Tax Relief Under the Families First and CARES Acts. 05/06/2020
- 420cpa.com blog
- The Mechanics of the Cannabis Cultivation Tax in California. 07/24/2020. With Abraham Finberg & Rachel Wright.
- Unpublished
- 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”
- 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"
Presentations (incomplete list)
I have given dozens of presentations from 1-3 hours to various audiences, including law firms; client groups; CalCPA local chapters; and networking groups. These include:
- **Presented my paper, “QOZ Planning When Penalties Are a Certainty” (see above) as part of the 2022 California Lawyers Association DC Delegation.
- Two presentations to CalCPA annual meeting, on NOLs (handout) and **QOZs (handout).
- Several presentations recorded by CA Continuing Education of the Bar (CEB). **Example.
- CalCPA: Coronavirus Legislation Contains Employment Tax Relief, and Mixed Messages.
- Where do Loopholes Come From? 08/28/2020 (Podcast - McKenna Brink)
- How to Understand, Mitigate, and Defend Tax Penalties 10/12/2021 (PodCast - Tax Girl)
- California Property 19: A (Slightly Technical) Introduction 12/26/2020 (solo presentation)
- **Seminar re QOZs 11/10/2021 (with Lerman Law Partners)
- Guest lecturer for David Rice for accounting students, Cal Poly Pomona (3 hours).
- **Novogradac Spring 2022 Opportunity Zones Conference (“Structuring Insights” panel)