• Corporate and Partnership Reorganizations
    • Mergers and Acquisitions – § 368, Treas. Reg. § 1.708-1(c)
    • Divisive Reorganizations (Spin-Offs, Split-Offs, and Split-Ups) – § 355, Treas. Reg. § 1.708-1(d)
    • § 338(h)(10) Elections
  • Partnership Taxation
    • Partnership Capital Accounts
    • § 754 Elections
    • Allocation Provisions in Partnership Agreements and Operating Agreements
    • Technical Terminations – § 708
  • Business Succession Planning
    • Optimizing Tax Efficiency of Transfers of Business Interests
      • Partnership and Corporate Recapitalizations
      • Restrictions on Transfer
      • Buy-Sell Agreements
      • Employment and Consulting Agreements
    • Streamlining transition of management responsibility from an owner to a junior generation and/or key employees
    • Contingency Planning (Death and Disability)
      • Formulating continuity plans in the event an owner or key employee is incapacitated or otherwise unavailable long-term
      • Key Man Life Insurance and Disability Insurance
    • Equalization of Inheritance
      • Preventing conflict between siblings, cousins, and other family members when only some work for the family business and others do not