Experience Highlights
Qualified Small Business Stock (QSBS) Sale Structuring and Tax Compliance
Advised fund manager on Qualified Small Business Stock (Internal Revenue Code §1202, “QSBS”) sale reporting and compliance, including eligibility analysis, transaction structuring, investor disclosures, and tax reporting.
Tax-Efficient Corporate Reorganization and Recapitalization for Middle-Market Business
Structured and implemented tax-efficient merger, reorganizations, and recapitalizations for closely held, middle-market operating business in South Florida, including partnership division, tax-free reorganization under Code § 368(a)(1)(D), equity sale, and contribution agreement.
Corporate, Tax, and Commercial Counsel for Emerging and Growth Company
Counseled emerging and growth company on corporate, tax, and commercial agreements, including employment agreements, affiliate agreements, marketing arrangements, and founder-level planning.
Private Foundation and Public Charity Formation with Tax-Exempt Status
Formed and advised private foundations and public charities, including governance, policies and procedures, and grantmaking programs, securing federal tax-exempt status. Currently provide ongoing compliance guidance.
Estate and Gift Tax Planning for High-Net-Worth Individuals and Families
Developed and executed advanced estate and gift tax planning strategies, including post-mortem planning, qualified disclaimers, and fiduciary settlement techniques to reduce transfer taxes and align beneficiary interests.
Trust Modifications and Nonjudicial Settlement Agreements for Complex Matters
Negotiated and documented nonjudicial settlement agreements and trust modifications, including valuation and allocation issues involving tax-favored and illiquid assets.
Tax-Advantaged Entity Structuring for Healthcare and Professional Service Providers
Structured tax-advantaged healthcare and professional service entities, including entity formation, compensation planning, and regulatory-sensitive ownership structures.
Philanthropic Structuring and Fiscal Sponsorships for Charitable Organizations
Advised charities and philanthropic initiatives on fiscal sponsorships, donor-advised structures, and nonprofit collaborations, including agreements with community foundations and related compliance matters.