I work collaboratively with CPAs, lawyers, investment advisors and their clients to create value and help protect businesses and family wealth from exposures such as taxes, family disputes, and lawsuits.
My clients include Fortune 500 and large privately held companies, successful entrepreneurs, and families with estates of eight to ten figures. Together, we focus on defining objectives and achieving measurable results.
Rather than practicing law in the traditional sense, I help clients realize greater value by focusing on the following consulting services:
- Plain Language Consulting
- Formulating and Refining Objectives
- Discovering Hidden Value
- Identifying Unrecognized Exposures
- Prioritizing Opportunities
- Designing Tax, Business and Family Wealth Solutions
- Formulating Tax Appeal & Litigation Strategies
My primary focus is to identify unrecognized issues and design solutions to difficult tax, business, and family wealth challenges. In this environment, every situation is unique, and it is impossible to simply duplicate a prior strategy or outcome. And, I observe a strict code of confidentiality and do not disclose client names or any other specific information without permission.
For these reasons, the following examples are necessarily general and are provided solely to illustrate the nature of my work and experience. They are not intended to suggest that similar results can be achieved in future engagements.
Preserving Family Wealth
- While working on a corporate planning project for an ultra-wealthy family, identified a unique tax saving opportunity and designed a plan to reduce the family’s wealth transfer tax exposure by more than $100 million and avoid additional estate taxes for multiple generations.
- For an elderly owner of stock in a bank holding company, designed an aggressive estate tax reduction plan and successfully defended the plan against an IRS challenge following the client’s death.
- For a wealthy real estate investor, designed a family entity structure to accomplish the client’s goals of maintaining a strong, consolidated balance sheet while allowing the transfer substantial value to trusts for the benefit of family members
- For the owners of a closely held oil company, reorganized the family business to reduce exposure to lawsuits and developed a structure to reduce the older generation’s estate tax burden
- For the owner of a closely held business, identified an unrecognized opportunity and designed a business succession plan that reduced the client’s income tax liability by more than $10 million
Enhancing Business Income and Value
- For a Fortune 500 Company, developed a contingency plan to mitigate a tax exposure associated with the client’s prior corporate reorganization and successfully defended the plan against IRS challenge
- For a wealthy private equity investor, identified an opportunity and designed a strategy to reduce the client’s investment losses by more than $6 million
- For a successful entrepreneur involved in a substantial valuation dispute with the IRS, developed an overall litigation strategy and formulated a new position regarding valuation methodology that the IRS Appeals Office adopted
- For a corporation engaged in a dispute with the IRS regarding use of corporate aircraft, developed litigation strategy and successfully defended the taxpayer’s position against an IRS challenge
- For a Fortune 500 Company, developed strategy and substantive positions in tax refund litigation regarding complex OID regulations and the uncertain treatment of contingent obligations