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Unlocking Success: The Strategy Behind Partnership Divisions for Tax Compliance

In the article that appeared in last month’s blog, I indicated that we utilize a structure that avoids the taxing authorities’ challenges to “drop and swap” transactions and, instead, that is structured to comply with an...more

Decoding Franchise Tax Board’s Hot Button Areas: Drops and Swaps and Post-Closing Refinancing

Those of us in California who give advice regarding the structuring of IRC Section 1031 like-kind tax-deferred exchanges of real property are well aware that the California Franchise Tax Board (FTB) has an active program of...more

F Reorganizations: The Good, The Bad, and the Wasteful

I. Introduction F reorganizations, much like the game of Othello, can take a minute to learn but a lifetime to master. They are often a critical part of structuring the purchase and sale of S corporations. As part of an F...more

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