Jake Thacher Email & Phone Number

Denver, Co, Us

Denver, Colorado, United States

• Report to Senior Director of Tax• Assisted in planning and implementing Section 351 disproportionate contribution of LLC units to an S corporation to release $42MM of trapped losses• Prepared calculations to determine the number of shares or percentage of LLC interest received in exchange for a contribution of property in three separate transactions• Analyzed application of Section 1031 in four transactions to determine if the structure qualifies for tax deferral• Structured disposition transactions to qualify for Section 1031 exchange• Researched and prepared a memorandum analyzing Section 355 spin-off transaction. Concluded the transaction did not meet the requirements, and recommended reporting transaction as taxable distribution, resulting in recognition of built-in gain under Section 311(b)• Reviewed physical and digital archives of legal documents and financial statements to recreate corporate history for audit purposes of three holding companies going back to 1986• Prepared payment schedules for four Section 467 leases• Assisted in planning for two sets of entity consolidations to reduce administrative burden and preserve federal tax attributes• Computed basis of partnerships and S corporations to determine tax consequences of transactions such as distributions and mergers• Provided support in researching and planning with respect to acquisitions, divestures, due diligence and other business transactions• Analyzed tax classification under Treas. Reg. Section 301.7701-2 and -3 of 200 domestic and foreign entities to ensure accurate responses to KYC inquiries by financial institutions• Aided in reviewing and structuring transactions to optimize tax consequences