Proactive tax planning relating to application of GCT on capital gains on NYC-based real estate held in legacy S Corp.  Mitigation structures and details of implementation both for current year and for out-year’s planning.  Trade-offs of tax savings against constraints on taxpayer behavior framed clearly for client.

Analysis of Like Kind Exchange and S. 121 exemption rules to property owned by a couple involved in cooperative divorce.  Structuring of optimal tax savings approach to property given relative ownership and use period and potential structuring for TIC interests and parallel 1031 transactions.

Documentation and strategy relating to inter vivos gift of New York coop held through an S Corporation, gift tax implications and filings and creation of new unanimous written consent and by laws for family recipient.