Our Story

Tax advisor/engagement leader for numerous ultra-high net worth families and their businesses. Represented more than 18 members of the Forbes 400 list, including 12 with significant presence in Florida. Others have been in Texas, Georgia, California, and Tennessee. Following is list of representative projects:

• Planning for the acquisition, disposition, and operations of five professional sports teams. Representation of these owners and their teams included annual tax compliance review and preparation; consulting on depreciation, amortization and accounting methods; income tax saving strategies in connection with sales of these significant assets; passive activity planning; charitable planning; estate tax administrative and valuation matters; research and development credit studies; and cost segregation studies.
• Lead partner on comprehensive and multi-faceted estate, gift and generation skipping planning projects for many of these families, saving hundreds of millions of transfer taxes; preserving family harmony and tranquility; succession planning for business holdings; establishing and providing guidelines for operating Private Foundations and charitable trusts; and planning projects for two, three or four generations of families. Led these engagements and worked with numerous outside teams of advisors from the most prominent professional service firms in the country (legal, insurance, investment, investment banking and valuation).
• Planning related to monetization and diversification of significant qualified and nonqualified stock options.
• Tax minimization consulting projects involving billions of dollars of gains attributable to disposition of significant family assets: valuation and other discount planning, charitable planning, tax deferral, and tax rate arbitrage.
• Tax compliance reviews of thousands of tax returns related to operating business partnerships, investment and family partnerships, S corporations, and C corporations, and public and private charitable entities. Issues addressed and tax savings opportunities from these reviews included, among other things, passive activity and at-risk basis planning; S corporation and partnership tax basis planning; significant savings related to investment management and otherwise non-deductible Itemized Deductions; strategies to minimize the impact of ordinary tax rates on significant income; tax recapture planning projects; capitalization studies under Sec. 263A and 266; studies involving purchase price allocations and basis step-ups, capitalization/deductibility of costs associated with acquisitions and dispositions.
• Significant industry expertise gained through these clients involved in real estate; construction; manufacturing and distribution; professional sports and entertainment; retail; private equity; and technology.

Through the representation of more than 300 other private business owners, ranging in net worth from $30 million to over $1 billion, developed technical expertise in many areas of tax law. These clients and their businesses are located throughout the United States.

• Clients have included very affluent and successful business owners in many industries, providing broad industry exposure and expertise. Representative clients include entrepreneurs and family business owners in the following industries: research, biotechnology and pharmaceutical; real estate families involved in all aspects of commercial, hospitality and residential real estate; medical and healthcare; oil and gas; agriculture and mining; software and technology; oil and gas; manufacturing and distribution; wholesalers; retail; private equity; hedge funds; and transportation. Many of these clients are third through seventh generation family businesses, with operations spanning more than 100 years.
• Represented several dozen private equity groups and portfolio companies. Assisted with structuring acquisitions, assisted sales of businesses, and analysis of numerous business and tax issues related to debt recapitalization projects.
• Gained a deep insight into both the sales and purchases of many private businesses, in a variety of structures. Tax savings projects for these businesses have included, among other things, research and development credit studies; state tax minimization projects; international tax structuring projects; cost segregation studies; Section 108/debt forgiveness planning and restructuring; partnership basis refreshing and planning; S corporation basis studies; accounting method and period reviews; and uniform capitalization projects (Sec. 263A).
• Personal tax planning projects included comprehensive estate, succession and family wealth planning projects, saving billions of dollars transfer taxes.
• Led tax planning projects for many sales of significant business assets, resulting in hundreds of millions of income tax savings. Sales of these businesses generally ranged from $20 million to over $1 billion. Projects involved planning for acquisitions and dispositions, Section 338 and 338(h)(10) basis planning projects, purchase price allocations, structuring transactions involving ESOP’s, and valuation planning.
• Establishing private foundations, support organizations, and donor advised funds.
• International tax planning projects including utilization of foreign tax credits; dealing with Subpart F income; Passive Foreign Investment Companies; FATCA filings and compliance; controlled foreign corporations; expatriation of profits from foreign entities; transfer pricing studies; Section 965 “Gilti” projects; and establishing entities abroad.
• Planning projects with tax favored and/or uniquely taxed investment vehicles, and financial products. These projects included analysis and planning associated with straddles, options, constructive sales, swaps and other synthetic equity investments.
• Sophisticated tax planning projects involving options for reporting millions of dollars of annual expenses and income associated with hedge fund and private equity investments. These projects included studies to maximize deductions associated with investment expenses; capitalization under Sec. 266/263A; reclassification to maximize tax savings; and analyzing trader vs. investor status. 
• Projects involving maximization of tax savings attributable to the business or rental use of planes and jets, yachts and racing boats, ranches, farmland, car collections, large residential estates and family compounds, and other significant personal use assets.
• Planning involving clients operating through partnership structures. Included in the scope of these projects: Sec. 704(c) capital account analysis; Sec. 704(d) basis studies; Debt analysis regarding recourse and nonrecourse debt and complex partnership allocations under Secs. 751 and 752; “hot asset” analysis under Sec. 751; substantial economic effect analysis under Sec. 704(b); sales of partnership interests involving numerous types of buyers, including tax exempt entities, foreign corporations and public and private company buyers; structuring transactions for sales to private equity firms; technical terminations; self-employment income; and aggregation of entities and businesses for purposes of the passive activity rules under Sec. 469.
• Complex planning involving net operating losses and carryback claims.
• Residency planning/state tax jurisdictional planning.
• Asset Protection Planning.
• Section 1202 research and analysis to capitalize on tax savings for exits of C corporation structures.
• Qualified Opportunity Zone studies and analysis. 
• Section 199A “pass through deduction” studies for privately held business owners in a variety of industries.
• Qualified conservation easements and complex reporting issues related to IRC Section 170(h) charitable deductions. These charitable planning strategies have saved clients many millions in income taxes. Also wrote formal tax opinions on such strategies.
• Representation of individuals and their businesses at all levels of the Internal Revenue Service and Treasury Department: field and desk audits, appeals and protests, private letter rulings, and dealings with the National Office.
• Planning involving clients operating through S corporations and ESOPs. Included in the scope of these projects: complex S corporation and shareholder basis studies; determination of qualified S corporation shareholders; validity and reaffirmation of S corporation elections, including IRS private letter rulings; S corporation conversions; and S corporation mergers and acquisitions.

• Involved in structuring, reporting, and establishing foundations devoted to horse therapy, artwork, museums, private automobile collections, real estate, and airplanes, in addition to more “traditional” liquid investment-based private foundations.
• Advised many large, well-established private foundations in Florida. This afforded the opportunity to have significant involvement in planning for unrelated business income (Sec. 512 and 513); Self-Dealing (Sec. 4941); Excess Business Holdings (Sec. 4943); Inurement and Private Benefit; and Jeopardizing Investments (Sec. 4944). Representation also included tax compliance reviews and planning associated with annual filings.
• Representative clients included The Knight Foundation; the Orange Bowl Foundation; MacArthur Foundation; Koch Foundation (large Catholic charity); Rossi Foundation (founder of Tropicana); multiple hospital foundations. Worked with many charitable entities in the hospital and healthcare industry.
• Representing these large, diversified healthcare organizations required extensive knowledge of not-for-profit tax law. It also required understanding the interplay with the for-profit aspects of these businesses. Projects included structuring numerous joint ventures/partnerships with medical equipment, supply and device partnerships; structuring joint ventures with physician groups; and gaining a deep understanding of highly technical tax rules as they apply to for-profit businesses conducted by tax exempt entities.
• Private letter rulings obtained from IRS for several of these clients involving tax exempt issues (UBTI; inurement and private benefit; self-dealing); a private letter ruling obtained for a supporting organization established for a therapeutic horse ranch established by a private client.
• Detailed analysis of transactions for purposes of “reportable transactions”, “listed transactions”, and “transactions of interest”. 
• Tax opinions authored on many of the issues involving transactions between private clients and their foundations or private charities. These opinions included tax issues involving self-dealing, private benefit and inurement, jeopardy investments, UBTI, assignment of income, and excess business holdings. Many of these charitable organizations were established as part of a more comprehensive income and estate tax planning project for the families listed above. These projects resulted in the establishment of dozens of private foundations and charitable trusts (CRT’s, CLT’s, etc.).

• Represented numerous private clients on issues involving Sec. 1091 wash sales.
• Represented numerous private clients involved in transactions requiring analysis of straddles and swaps (Secs. 1256, 1092), prepaid variable forward contracts (Sec. 1260), notional principal contracts (Secs. 446, 1001, 1256), and various forms of derivatives.
• Wrote formal tax opinions for private clients implementing investment strategies using sophisticated financial trades. These types of trades included swaps, debt-for-debt exchanges, notional principal contracts, complex option and debt-leveraged investments.
• Wrote several complex memoranda regarding non-traditional investments by Individual Retirement Plans (“regular” and Roth) and Qualified Retirement Plans, including operating businesses and unique assets owned by such plans, as well as various charitable trusts.
• Represented private clients investing in foreign currency, IRC Sec. 988 investments, and hedging transactions.
• Tax planning projects for private clients investing in Sec. 1256 futures contracts, prepaid variable forward contracts, and similar tax deferral strategies related to large, non-diversified investment positions.

• Leadership highlights of Arthur Andersen Private Client Services (PCS) Practice
  • Built and led Florida PCS team from its inception in 1993, with six members, growing to 22 members in 2002.
  • Developed and mentored two senior individuals that became partners in the practice.
  • Led Florida Quality Assurance initiative for over a dozen years for the entire tax practice, in recognition of deep technical skills and appreciation for quality and technical excellence, and risk management qualifications.
  • Participated with Regional Tax Practice Leaders in inter-office technical reviews of eight other offices, throughout the U.S. I was involved in these teams for over 15 years.
  • Led many PCS tax technical training sessions for the firm, both on a national and regional basis. Frequent national presenter and lecturer, both internally and externally. Developed content, presented, and mentored others to help them in developing technical skills, content and presentation skills.
  • Led 10 person Orlando federal tax practice, as sole tax partner responsible for that office.
• Leadership highlights from Montgomery Coscia Greilich LLP (2015 to 2018)
  • Led 20-person Flow Through Tax group, and worked with 125 other tax professionals in Corporate Tax, High Net Worth, and Enterprises Services Group
  • Group handled all the complex partnership allocations; 704(b) and 704(c) allocations; self-employment tax issues; tiered partnership and complex waterfall allocations; structuring dozens of new entities; sales and dispositions of private equity portfolio companies; and dozens of acquisitions and restructurings of private equity portfolio companies.
  • Firm-wide technical resource for all Subchapter K matters.
  • Firm-wide technical resource for all Subchapter S matters.
  • Developed and lead firm-wide training on numerous technical training topics through MCGU. Developed more than 12 Subchapter K technical training sessions for the firm.
  • Significant development of new work for practice, resulting in more than $1.4 million of new client work during 2016.