Income Taxation

Representative Experience

• Like-Kind Exchanges – Advised client on structuring complex multi-property, multi-entity deferred like-kind exchange under IRC Section 1031 in connection with multi-million dollar acquisition and dispositions of real property.  Structuring techniques involved use of disregarded entities, cancellation of indebtedness income (and related exemption provisions), and tenants in common (TIC) interests.

• Net Operating Loss Limitations – Advised client regarding net operating loss utilization limitations under IRC Sections 382 and 383 in connection with $50M+ acquisition transaction.  Provided underlying spreadsheet analyses and counseled client regarding potential means of avoiding imposition of limitations.  

• Golden Parachute Payments – Assisted client regarding analysis of golden parachute payments under IRC Section 280G in connection with acquisition of publicly traded company.  Client successfully avoided imposition of excise taxes for compensation received by executives and management team.

• Anti-Churning Rules – Advised clients regarding imposition of anti-churning rules under Code Section 197 and assisted client with restructuring to avoid loss of amortization/depreciation deductions in connection with acquisition of partnerships and LLCs.