Discussions and analysis of proper tax reporting of ownership of property and entities in the context of ongoing litigation of probate of estate.  Review of both tax rules and prima facie application of both EPTL provisions and application of trust documents in play with respect to entity ownership.  Guidance on best course of action both in relation to tax reporting and to implications of tax reporting on Surrogate’s Court presentation of income and ownership information.

Multiple transactions involving in-kind distribution of TIC interests through multiple layers of GP-LP partnerships in order to implement partial and/or parallel 1031 transactions.  Drafting of partnership (LLC) agreement language to account for in-kind distributions, review of TIC agreements and analysis of IRS rules and rulings relating to distribution and later transfer for nonrecognition treatment under S. 1031.

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.