Tax Free Corporate Reorganizations — Lead attorney for sellers in Forward Triangular and Reverse Triangular mergers under Section 368 of the Internal Revenue Code. Also involved complicated Section 351 issues and issues arising from Canadian purchasers.
Liquidating Trustee — Served as liquidating trustee for large non-profit insurance company that used Maine insurance statute to convert and merge with for-profit insurance company. The primary assets of the liquidating trust were significant income tax refunds. Participated in test cases and litigation settlement with IRS Served as liquidating trustee for eight years. Substantial interactions with Maine Bureau of Insurance and Maine Attorney General''s office.
Business Succession Planning — Succession planning for middle market corporations, both family owned and unrelated owners. Involved complicated federal and state income, excise, estate and gift tax issues. Also involved complicated valuation and choice of entity issues. Also involved complicated relationship dynamics.
Succession Planning for Real Estate — Used LLC to plan for valuable family owned real estate. Involves complicated tax issues, particularly estate and gift tax issues. Also involves mitigating stresses on the family arising from the cost of maintenance, the different levels of use by family members, and the desire of some family members to be bought out.