Cases
Experience: Representative Matters: Assisted in the proposed sale of a $600 million closely-held international publishing company
the funding of a private foundation
several charitable trusts that own stock in the company
its subsidiaries.
Assisted in numerous valuations of national
international closely-held businesses for purposes of discounted gifting of minority interests in the related company, including (i) a $350 million systems integrator providing advance IT, telecommunications, systems engineering solutions
services to the Federal government
(ii) a $180 million global leader in telecom
information technology
(iii) a $75 million technology company
(iv) a $35 million commercial printing company.
Implemented strategies
plans to qualify for the favorable estate tax deferral provisions in a potential $200 million estate that owned primarily closely-held shares of a specialist firm on the floor of the New York Stock Exchange.
Implemented
funded several charitable remainder trusts, charitable lead trusts (both grantor
nongrantor)
private foundation (including operating
non-operating).
Researched QSST
ESBT eligibility for several Crummey trusts that owned shares in a closely-held corporation considering converting to a S-corporation.
Petitioned a local state court to divide a deceased husb
's residuary marital trust into separate trusts to file a partial QTIP election to take advantage of the decedent's available estate tax credits
exemptions.
Reviewed U.S. estate
income taxation of a U.S. beneficiary of assets from a deceased German domiciliary.
Assisted in the drafting
funding of several irrevocable trusts designed to avoid the application of the Florida intangibles tax to Florida resident clients.
Assisted in the filing of qualified disclaimers by several beneficiaries of a deceased IRA participant to accomplish an approved spousal rollover of the $1.5 million IRA asset.
Assisted in the filing of a qualified disclaimer by a Personal Representative of the second spouse to die's estate to take maximum advantage of both deceased spouse's unified credit amounts.
Obtained federal tax exempt status for a testamentary charitable trust that failed to contain all of the required language in the governing instrument to qualify as a private foundation.
Participated in the reformation of a $500,000 NIMCRUT to a flip CRT.
Noteworthy Experiences: Legal Intern, United States Attorney's Office, Narcotics Division, Washington, D.C., 1993-1994
Legal Intern, State's Attorney's Office, Montgomery County, MD, 1993