Experience Category: Tax Planning

Tax Planning for 1031 Partial Exchanges of Strip Mall

Tax planning for distribution of TIC interests and partial 1031 exchanges from certain ownership stakes of strip mall held in tiered partnership structure.  Drafting LLC language and TIC agreement and reviewing transfer and dissolution documents RE: same.

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.

Planning Around GCT Application to RE Held in S Corporation

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.
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