Jeffrey Haskell Email & Phone Number

Fairfield, Ct, Us

As Chief Legal Officer the nation’s largest provider of comprehensive support services for private foundations, I coordinate with other departments to ensure compliance with legal and regulatory requirements, reduce institutional risk, and enhance client service. I oversee: • Review of contracts • Compliance with legal and ethical requirements, including with respect to state and federal tax and regulatory filings • Evaluation of policies, procedures, and operations • Advice and assistance to foundation clients regarding tax and regulatory compliance. From foundation formation and throughout the various stages of a foundation’s evolution, I help Foundation Source establish and maintain the legal and regulatory framework to help foundations and their founders balance their desire for transformative impact with the requirements of federal and state law. I also serve as an ambassador and legal expert representing Foundation Source by publishing articles and participating in webinars and conferences related to private foundations.

Fairfield, Ct, Us

Fairfield, Ct, Us

Fairfield, Ct, Us

Palo Alto, Ca, Us

Researched and drafted memorandum regarding the application of Internal Revenue Code Section 2701 to the proposed recapitalization of a closely-held corporation. Researched case law and technical advice memoranda regarding the application of Internal Revenue Code Section 2703 to family limited partnerships. Prepared interrelated computations to determine an estate’s outstanding Federal and New York State estate tax liability pursuant to Internal Revenue Code Section 6166 in order to amend the estate’s estate tax returns. Compiled and reviewed documents in preparation for a Federal estate tax audit and subsequently met and negotiated with examiner. Drafted Wills, IRS Trusts, Trusts for grandchildren, Life Insurance Trusts and “Pot” Trust for descendants.

New York, New York, Us

Prepared request for and obtained a favorable private letter ruling in connection with an Internal Revenue Code Section 355 “split-off.” Drafted like-kind exchange documents and modified contracts of sale in connection with deferred exchanges and coordinated all tax aspects of the closings of the relinquished and replacement properties. Performed Internal Revenue Code Section 382 analyses to determine maximum amount of stock that could be purchased without incurring adverse tax consequences. Reviewed and modified incentive stock plans. Participated in tax litigation in the Tax Court and the United States Court of Appeals regarding the liability of an “innocent spouse,” the reasonableness of the amount of compensation paid to corporate executives, and the deductibility of certain expenses incurred by a corporation. Researched various merger, tax-free reorganization, stock redemption, tax-free stock dividend and other corporate tax issues.

New York, Ny, Us

Prepared and delivered lectures and drafted midterm and final examinations for graduate students, covering “spin-offs,” tax-free reorganizations, taxable corporate acquisitions, liquidations, redemptions, tax-free stock dividends and related subjects.

Participated in negotiations, due diligence, preparation of operative loan documents for refinancing, the acquisition of loan portfolios in excess of $500 million, and construction loans for shopping centers, office buildings and tracts of raw land. Drafted corporate resolutions and partnership consents authorizing various real property acquisitions, mergers, loans and pledges of company stock or partnership interests, as applicable. Prepared and reviewed promissory notes, mortgages, loan agreements, hazardous waste indemnities, leases, uniform commercial code financing statements, and corporation, partnership and limited liability company pledge agreements. Formed limited liability companies, corporations, and limited and general partnerships.

Gb

Researched and drafted memoranda regarding a variety of Federal and international tax issues including: C corporation conversion to an LLC, barter transactions, debt-versus-equity issues, taxability of reorganization plans, multiple-party like-kind exchanges, original issue discount, below-market loans, partnership formation and termination issues, limitations on deductibility of interest payments to related foreign parties and whether such income was United States-source income effectively connected with a United States trade or business. Corresponded with the Internal Revenue Service and participated in negotiations on behalf of client pursuant to an Internal Revenue Service audit. Participated in several research and experimentation tax credit studies for leading pharmaceutical, insurance, finance, tobacco and telecommunication companies.

Ll.M., Taxation

J.D., Magna Cum Laude, Tax Law

B.A., Magna Cum Laude, Political Science

A.A., Magna Cum Laude, General Judaic Studies