Of Counsel
CurrentMichael’s practical and litigation experience, combined with his knowledge of tax laws both here and abroad, make him a powerful advocate for his clients’ best interests. He is particularly skilled in tax planning for individuals and business entities, estate planning and asset protection strategies.Clients outside of the United States value Michael’s experience in international transactions to guide them in making investments in this country. Michael represents clients in tax audits and appeals before the International Revenue Service and federal and state courts. Recent matters that have been favorably settled include:• Tax Court cases involving the validity of a family limited partnership and appropriate estate tax valuation discount; and the validity of a late-filed election to exclude foreign source income. • In District Court, settlement was reached in a case in which the government sought to reduce an assessment to judgment for a responsible person assessment for employment taxes. • Following a trial before the New York State Division of Tax Appeals, Michael resolved a responsible person assessment for New York sales tax.• A New York State Department of Taxation and Finance ruling, in a matter of first impression, that the Units in the Trump-SoHo Hotel Condominium are not subject to the New York State Mansion Tax. The Mansion Tax, New York Tax Law Section 1402-a, is an additional real property tax payable by purchaser of conveyances of residential real property when the consideration exceeds one million dollars. The ruling determined that the hotel-condominium units are not residential property for the purposes of the Mansion Tax.• In a Tax Court proceeding involving the treatment of stock options received as compensation, the government conceded its case.Michael’s practice is focused in the areas of:• Audits and Appeals• Charitable Planning • Estate & Trust Administration• Estate & Gift Planning• Tax Litigation• Tax Law• Trusts and Estates
