I am brought in by lawyers and CPAs to help them identify, mitigate, and (where all else fails) allocate the tax risks and benefits in their clients' business and personal transactions.
Education and Affiliations
- NYU SCHOOL OF LAW, LL.M. in Taxation, 2016.
- NYU STERN SCHOOL OF BUSINESS, Certificate in Law & Business.
- COLUMBIA LAW SCHOOL, J.D., 2011.
- STANFORD UNIVERSITY, B.A. (History), 2006.
CA Tax Specialist exam, passed 3/22 (admission pending approval)
LA Lawyer's Philharmonic (cello)
Volunteer, Bet Tzedek Low-Income Taxpayer Clinic
All errors in these articles are mine and mine alone, except for the typographical errors; these were added by the editors of the respective publications.
Articles about Opportunity Zones have asterisks**.
- Tax Notes
- **How Forgiving Recapture Gain Turns QOZs into Tax Shelters. 11/25/19.
- **Incremental OZ Reform Could Be a Step Backward. (letter to the editor) 5/9/22.
- California Tax Lawyer (Publication of the California Lawyers Association - Taxation Section)
- **QOZ Planning When Penalties are a Certainty. Accepted for publication (2022).
- **Personal Goodwill For New QO Funds, Business Goodwill For Old Ones: IRS May Cry “Whipsaw". February 2022.
- Bloomberg Insights
- Deferring Tax with IRC 453, Without Crossing the Line. 5/2/22.
- **Using a Qualified Opportunity Fund to Invest in non-QOZ Property. 03/15/2022.
- Cannabis Taxpayers Find Flaws in New Section 471(c) Regs. With AB FinWright, LLP. 03/11/2021
- Hidden Tax Dangers in Cannabis Outsourcing Arrangements. With AB FinWright, LLP. 09/15/2021
- Bloomberg Tax Journals
- The Installment Method: Misuses that Make Me Lose Sleep. Real Estate Journal (accepted for publication).
- **What Good is OZ Reporting if We Don’t Agree on the Goals? Real Estate Journal, 03/16/2022.
- Family Offices Allow (Some) Taxpayers to Deduct Investment Related Expenses. Estates, Gift, and Trusts Journal, 03/12/20. With Alan S. Gassman et al.
- CEB Reporters
- QSBS Letters: Best (and Worst) Practices. Business Law Reporter. March 2022.
- Avoiding California Taxation: Considerations for Individuals Currently Domiciled in the State. Business Law Reporter. July 2021.
- Trustee's Personal Liability for Estate Taxes. Estate Planning & California Probate Reporter. November 2021.
- Real Estate Tax Tips During Coronavirus. Real Property Law Reporter. May 2020.
- Coronavirus Legislation Contains Employment Tax Relief, and Mixed Messages. Business Law Reporter. July 2020.
- California Taxation (Sep. 2020) Case Summary. 42 Cal. Bus. L. Rep. 2
- LA Daily Journal
- If you squander this once-in-a-lifetime chance to make tax-free gifts, you're not a bad person. 11/02/2021.
- **QOZ projects have ‘up to’ 24 more months due to COVID-19. 03/19/20. With Michael Wiener.
- **Treasury Releases Long-Awaited QOZ Regulations. 04/19/19. With Neda Barkhordar.
- Should You Change Your Accounting Method? An Emerging Cannabis Loophole. With AB FinWright, LLP. 06/16/2020
- Quoted in
- Wall Street Journal, IRS Says Tax-Free Maltese Pensions Are Too Good to Be True. 12/21/2021
- Your Tax Matters Partner blog
- CEB (CA Continuing Education of the Bar) blog
- **IRS Releases Generous Guidance for QOZs During Coronavirus Pandemic.
- **Poking Holes in the Final QOZ Regulations. 01/30/20.
- Limits on the Installment Method of Accounting for Gain. 10/15/2020.
- California Passes Partial Tax Conformity Bill, Raising More Questions. 10/17/19.
- Split Roll Ballot Measure Could Scale Back Proposition 13. 10/01/2020
- Employment Tax Relief Under the Families First and CARES Acts. 05/06/2020
- 420cpa.com blog
- The Mechanics of the Cannabis Cultivation Tax in California. 07/24/2020. With Abraham Finberg & Rachel Wright.
- Update author for publications by CEB (CA Continuing Education of the Bar):
- Advising California Employers and Employees - chapter 7, “Tax Compliance”
- Advising California Partnerships - chapter 3, “Tax Considerations on Formation of and Contributions to Partnership”
- Advising California Partnerships - chapter 14, “Taxation of Transfers and Terminations of Partnership Interests”
- Business Buy-Sell Agreements - chapter 3, “Corporate Buy-Sell Agreements”
- Drafting California Irrevocable Trusts - chapter 14, “Grantor Retained Income Trusts (GRITs)"
- Drafting California Irrevocable Trusts - chapter 15, “Grantor Retained Annuity Trusts (GRATs)”
- Organizing Corporations in California - chapter 1, "Considerations Before Incorporation"
- Organizing Corporations in California - chapter 2A, “Conversions and Mergers”
- Trade Secrets Practice in California - chapter 15, "Taxation of Trade Secrets"
Presentations (incomplete list)
I have given dozens of presentations from 1-3 hours to various audiences, including law firms; client groups; CalCPA local chapters; and networking groups. These include:
- **Presented my paper, “QOZ Planning When Penalties Are a Certainty” (see above) as part of the 2022 California Lawyers Association DC Delegation.
- Two presentations to CalCPA annual meeting, on NOLs (handout) and **QOZs (handout).
- Several presentations recorded by CA Continuing Education of the Bar (CEB). **Example.
- CalCPA: Coronavirus Legislation Contains Employment Tax Relief, and Mixed Messages.
- Where do Loopholes Come From? 08/28/2020 (Podcast - McKenna Brink)
- How to Understand, Mitigate, and Defend Tax Penalties 10/12/2021 (PodCast - Tax Girl)
- California Property 19: A (Slightly Technical) Introduction 12/26/2020 (solo presentation)
- **Seminar re QOZs 11/10/2021 (with Lerman Law Partners)
- Guest lecturer for David Rice for accounting students, Cal Poly Pomona (3 hours).
- **Novogradac Spring 2022 Opportunity Zones Conference (“Structuring Insights” panel)