About my practice
I advise clients on tax planning.
- I counsel individuals, businesses, and their lawyers and CPAs at key moments--entity formation, retention of key employees, sale of property, reorganization, and exit from business.
- I draft and review operating agreements, purchase agreements, compensation plans, etc. to identify, mitigate, and/or allocate tax risks and benefits.
- I prepare short research memos and detailed written opinions to reassure CPAs and investors about substantive tax obligations and filing requirements.
- 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
- Tax Notes
- How Forgiving Recapture Gain Turns QOZs into Tax Shelters. Front page article 11/25/19.
- Bloomberg Insights
- Bloomberg Tax: Estates, Gift, and Trusts Journal:
- Family Offices Allow (Some) Taxpayers to Deduct Investment Related Expenses. 03/12/20. With Alan S. Gassman, John N. Beck, and Christopher J. Denicolo.
- CEB Reporters
- Real Estate Tax Tips During Coronavirus. CEB Real Property Law Reporter. May 2020.
- Avoiding California Taxation: Considerations for Individuals Currently Domiciled in the State. CEB Business Law Reporter. July 2021.
- Coronavirus Legislation Contains Employment Tax Relief, and Mixed Messages. CEB Business Law Reporter. July 2020.
- LA Daily Journal
- 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 Abraham Finberg and Rachel Wright.
- CEB blog
- Presentation / Handouts (incomplete list)
- CEB Update
- "Tax Considerations on Formation of and Contributions to Partnership";
- "Taxation of Transfers and Termination of Partnership Interests";
- "Corporate Buy-Sell Agreements"
- “Taxation of Trade Secrets”.
- "Grantor Retained Income Trusts".
- "Grantor Retained Annuity Trusts"
- Tax Loopholes
- Tax Girl (pending)
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 expatriates
- 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.