Contributions to Books (12)
A Hitchhiker's Guide to International Estate Planning: Estate Planning for United States Citizens with Assets Abroad and for Nonresidents with United States Assets ACTEC Law Journal (2008)
This article offers an overview of the common estate planning issues faced by practitioners when their clients are U.S. citizens with business and investment activates outside the U.S. or nonresidents with U.S. business or investment ...
Liquidation of the Family Partnership: The Taming of the Shrewd Practical Tax Lawyer (2006)
Family partnerships and family limited liability companies are typically formed for reasons of efficiency, succession, and valuation. But all good things come to an end. Owners of a family partnership opt for liquidation in a ...
Super-Recognition and the Return-to-Sender Exception: The Federal Income Tax Problems of Liquidating the Family Limited Partnership Capital University Law Review (2006)
This article discusses three income tax rules that can cause partners to recognize gain for federal income tax purposes upon the liquidation of a family limited partnership: §§ 704(c)(1)(B), 731(c), and 737. From a policy ...