Experience Category: Individuals

Structuring Settlement Payments for Tax Savings

Multiple situations involving investigating potential structures of settlement payments for potential tax savings relating to applicable above-the-line statutory expense deductions, application of FICA, miscellaneous itemized deductions/pursuit of income determination and independent contractor determinations and potential expense apportionment possibilities.

Tax Efficient Structure for Panamanian Development

Analysis and recommendation for tax efficient receipt of payments and profits for US citizen developing real estate properties in Panama business zone.  Application of S. 911 rules, debt and equity characterization and look-through vs. corporate taxation of profits on realization of project.

Structuring Silent Minority Investment

Structuring and documenting minority investment in small business for desired economic results and discretion of identities of parties and amounts at stake.  Planning and implementation of same.
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