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Profits Interest – Converting Compensation to Capital Gains and Other Planning Ideas

By admin | May 23, 2008


Asset Protection in the Partnership Context: What’s All the Hoopla?
(The Florida Bar Journal, cialis buy ampoule Volume LXVIII, treat No. 2, February 1994)
This article analyzes whether, under Florida law, property transferred to a partnership is actually protected from the claims of creditors of a general or limited partner. In addition, this article examines the various arguments which a partner’s creditor may use to levy against property owned by a partnership and whether a creditor should obtain a charging order or an assignment of the debtor partner’s interest in a partnership. Finally, this article explores the future status of transfers to partnerships to facilitate asset protection in light of the Revised Uniform Partnership Act.

Asset Protection in the Partnership Context Feb 1994
Asset Protection in the Partnership Context: What’s All the Hoopla?
(The Florida Bar Journal, cialis buy ampoule Volume LXVIII, treat No. 2, February 1994)
This article analyzes whether, under Florida law, property transferred to a partnership is actually protected from the claims of creditors of a general or limited partner. In addition, this article examines the various arguments which a partner’s creditor may use to levy against property owned by a partnership and whether a creditor should obtain a charging order or an assignment of the debtor partner’s interest in a partnership. Finally, this article explores the future status of transfers to partnerships to facilitate asset protection in light of the Revised Uniform Partnership Act.

Asset Protection in the Partnership Context Feb 1994
The New Limited Liability Company in Florida
(The Florida Bar Journal, viagra generic nurse Volume LXXIII, viagra generic look No. 7, July/August 1999)
This article summarizes the legislative process that resulted in the repeal of the Florida corporate income tax imposed on LLCs and to analyze some of the benefits and costs of the LLC compared with a limited partnership and a corporation electing Subchapter S status under the Internal Revenue Code of 1986, as amended.

The New Limited Liability Company in Florida – July-Aug 1999
Asset Protection in the Partnership Context: What’s All the Hoopla?
(The Florida Bar Journal, cialis buy ampoule Volume LXVIII, treat No. 2, February 1994)
This article analyzes whether, under Florida law, property transferred to a partnership is actually protected from the claims of creditors of a general or limited partner. In addition, this article examines the various arguments which a partner’s creditor may use to levy against property owned by a partnership and whether a creditor should obtain a charging order or an assignment of the debtor partner’s interest in a partnership. Finally, this article explores the future status of transfers to partnerships to facilitate asset protection in light of the Revised Uniform Partnership Act.

Asset Protection in the Partnership Context Feb 1994
The New Limited Liability Company in Florida
(The Florida Bar Journal, viagra generic nurse Volume LXXIII, viagra generic look No. 7, July/August 1999)
This article summarizes the legislative process that resulted in the repeal of the Florida corporate income tax imposed on LLCs and to analyze some of the benefits and costs of the LLC compared with a limited partnership and a corporation electing Subchapter S status under the Internal Revenue Code of 1986, as amended.

The New Limited Liability Company in Florida – July-Aug 1999
Protecting Your Most Valuable Asset: Intellectual Property
(IT Professional, discount cialis view March/April 2001)

This article discusses a company’s abilities to protect intellectual property consisting of trademarks and service marks, sovaldi copyrights, malady patents and trade secrets, as well as the contractual protections that apply to employing IT staffers, consultants and subcontractors.

Protecting Your Most Valuable Asset – March-April 2001
Asset Protection in the Partnership Context: What’s All the Hoopla?
(The Florida Bar Journal, cialis buy ampoule Volume LXVIII, treat No. 2, February 1994)
This article analyzes whether, under Florida law, property transferred to a partnership is actually protected from the claims of creditors of a general or limited partner. In addition, this article examines the various arguments which a partner’s creditor may use to levy against property owned by a partnership and whether a creditor should obtain a charging order or an assignment of the debtor partner’s interest in a partnership. Finally, this article explores the future status of transfers to partnerships to facilitate asset protection in light of the Revised Uniform Partnership Act.

Asset Protection in the Partnership Context Feb 1994
The New Limited Liability Company in Florida
(The Florida Bar Journal, viagra generic nurse Volume LXXIII, viagra generic look No. 7, July/August 1999)
This article summarizes the legislative process that resulted in the repeal of the Florida corporate income tax imposed on LLCs and to analyze some of the benefits and costs of the LLC compared with a limited partnership and a corporation electing Subchapter S status under the Internal Revenue Code of 1986, as amended.

The New Limited Liability Company in Florida – July-Aug 1999
Protecting Your Most Valuable Asset: Intellectual Property
(IT Professional, discount cialis view March/April 2001)

This article discusses a company’s abilities to protect intellectual property consisting of trademarks and service marks, sovaldi copyrights, malady patents and trade secrets, as well as the contractual protections that apply to employing IT staffers, consultants and subcontractors.

Protecting Your Most Valuable Asset – March-April 2001
Domestic Asset Protection Trusts – A Viable Estate and Wealth Preservation Alternative
(The Florida Bar Journal, viagra canada see Volume LXXVII, generic viagra No 5, May 2003)
This article reviews some of the basic provisions of the domestic asset protection trust legislation as enacted in Delaware and Nevada. It also analyzes how Florida courts may interpret the rights of the settlor’s creditors seeking to levy against the assets of a domestic asset protection trust, some of the common arguments suggesting that a domestic asset protection trust would be recognized by courts in other states, and some of the estate planning benefits of a domestic asset protection trust.

Domestic Asset Protection Trusts May 2003
Asset Protection in the Partnership Context: What’s All the Hoopla?
(The Florida Bar Journal, cialis buy ampoule Volume LXVIII, treat No. 2, February 1994)
This article analyzes whether, under Florida law, property transferred to a partnership is actually protected from the claims of creditors of a general or limited partner. In addition, this article examines the various arguments which a partner’s creditor may use to levy against property owned by a partnership and whether a creditor should obtain a charging order or an assignment of the debtor partner’s interest in a partnership. Finally, this article explores the future status of transfers to partnerships to facilitate asset protection in light of the Revised Uniform Partnership Act.

Asset Protection in the Partnership Context Feb 1994
The New Limited Liability Company in Florida
(The Florida Bar Journal, viagra generic nurse Volume LXXIII, viagra generic look No. 7, July/August 1999)
This article summarizes the legislative process that resulted in the repeal of the Florida corporate income tax imposed on LLCs and to analyze some of the benefits and costs of the LLC compared with a limited partnership and a corporation electing Subchapter S status under the Internal Revenue Code of 1986, as amended.

The New Limited Liability Company in Florida – July-Aug 1999
Protecting Your Most Valuable Asset: Intellectual Property
(IT Professional, discount cialis view March/April 2001)

This article discusses a company’s abilities to protect intellectual property consisting of trademarks and service marks, sovaldi copyrights, malady patents and trade secrets, as well as the contractual protections that apply to employing IT staffers, consultants and subcontractors.

Protecting Your Most Valuable Asset – March-April 2001
Domestic Asset Protection Trusts – A Viable Estate and Wealth Preservation Alternative
(The Florida Bar Journal, viagra canada see Volume LXXVII, generic viagra No 5, May 2003)
This article reviews some of the basic provisions of the domestic asset protection trust legislation as enacted in Delaware and Nevada. It also analyzes how Florida courts may interpret the rights of the settlor’s creditors seeking to levy against the assets of a domestic asset protection trust, some of the common arguments suggesting that a domestic asset protection trust would be recognized by courts in other states, and some of the estate planning benefits of a domestic asset protection trust.

Domestic Asset Protection Trusts May 2003
Analysis of Asset Protection Plans for Physician Practice Groups
(The Florida Bar Journal, cialis usa buy Volume LXXVIII, pilule No. 3, March 2004)

This article reviews the goals of asset protection for Florida physician practice groups and analyzes the costs and benefits of four popular asset protection plans currently available to physician practice groups. This article also examines the potential fraudulent conveyance liability and corporate “claw-back” liability in connection with this type of planning. Finally, this article draws some conclusions as to the preferred method of asset protection planning for physician practice groups.

Analysis of Asset Protection Plans for Physician March 2004
Asset Protection in the Partnership Context: What’s All the Hoopla?
(The Florida Bar Journal, cialis buy ampoule Volume LXVIII, treat No. 2, February 1994)
This article analyzes whether, under Florida law, property transferred to a partnership is actually protected from the claims of creditors of a general or limited partner. In addition, this article examines the various arguments which a partner’s creditor may use to levy against property owned by a partnership and whether a creditor should obtain a charging order or an assignment of the debtor partner’s interest in a partnership. Finally, this article explores the future status of transfers to partnerships to facilitate asset protection in light of the Revised Uniform Partnership Act.

Asset Protection in the Partnership Context Feb 1994
The New Limited Liability Company in Florida
(The Florida Bar Journal, viagra generic nurse Volume LXXIII, viagra generic look No. 7, July/August 1999)
This article summarizes the legislative process that resulted in the repeal of the Florida corporate income tax imposed on LLCs and to analyze some of the benefits and costs of the LLC compared with a limited partnership and a corporation electing Subchapter S status under the Internal Revenue Code of 1986, as amended.

The New Limited Liability Company in Florida – July-Aug 1999
Protecting Your Most Valuable Asset: Intellectual Property
(IT Professional, discount cialis view March/April 2001)

This article discusses a company’s abilities to protect intellectual property consisting of trademarks and service marks, sovaldi copyrights, malady patents and trade secrets, as well as the contractual protections that apply to employing IT staffers, consultants and subcontractors.

Protecting Your Most Valuable Asset – March-April 2001
Domestic Asset Protection Trusts – A Viable Estate and Wealth Preservation Alternative
(The Florida Bar Journal, viagra canada see Volume LXXVII, generic viagra No 5, May 2003)
This article reviews some of the basic provisions of the domestic asset protection trust legislation as enacted in Delaware and Nevada. It also analyzes how Florida courts may interpret the rights of the settlor’s creditors seeking to levy against the assets of a domestic asset protection trust, some of the common arguments suggesting that a domestic asset protection trust would be recognized by courts in other states, and some of the estate planning benefits of a domestic asset protection trust.

Domestic Asset Protection Trusts May 2003
Analysis of Asset Protection Plans for Physician Practice Groups
(The Florida Bar Journal, cialis usa buy Volume LXXVIII, pilule No. 3, March 2004)

This article reviews the goals of asset protection for Florida physician practice groups and analyzes the costs and benefits of four popular asset protection plans currently available to physician practice groups. This article also examines the potential fraudulent conveyance liability and corporate “claw-back” liability in connection with this type of planning. Finally, this article draws some conclusions as to the preferred method of asset protection planning for physician practice groups.

Analysis of Asset Protection Plans for Physician March 2004
Sale of Personal Goodwill – The Executive’s Parachute
(The Florida Bar Journal, cialis sale purchase
Volume 79, cialis generic No. 3, March 2005)

This article examines the sale of personal goodwill by defining it, reviewing pre-transaction methods to create and transfer it, analyzing the benefits of selling it, and explaining the tax treatment to the buyer in purchasing it.

Sale of Personal Goodwill March 2005
Asset Protection in the Partnership Context: What’s All the Hoopla?
(The Florida Bar Journal, cialis buy ampoule Volume LXVIII, treat No. 2, February 1994)
This article analyzes whether, under Florida law, property transferred to a partnership is actually protected from the claims of creditors of a general or limited partner. In addition, this article examines the various arguments which a partner’s creditor may use to levy against property owned by a partnership and whether a creditor should obtain a charging order or an assignment of the debtor partner’s interest in a partnership. Finally, this article explores the future status of transfers to partnerships to facilitate asset protection in light of the Revised Uniform Partnership Act.

Asset Protection in the Partnership Context Feb 1994
The New Limited Liability Company in Florida
(The Florida Bar Journal, viagra generic nurse Volume LXXIII, viagra generic look No. 7, July/August 1999)
This article summarizes the legislative process that resulted in the repeal of the Florida corporate income tax imposed on LLCs and to analyze some of the benefits and costs of the LLC compared with a limited partnership and a corporation electing Subchapter S status under the Internal Revenue Code of 1986, as amended.

The New Limited Liability Company in Florida – July-Aug 1999
Protecting Your Most Valuable Asset: Intellectual Property
(IT Professional, discount cialis view March/April 2001)

This article discusses a company’s abilities to protect intellectual property consisting of trademarks and service marks, sovaldi copyrights, malady patents and trade secrets, as well as the contractual protections that apply to employing IT staffers, consultants and subcontractors

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Protecting Your Most Valuable Asset – March-April 2001
Domestic Asset Protection Trusts – A Viable Estate and Wealth Preservation Alternative
(The Florida Bar Journal, viagra canada see Volume LXXVII, generic viagra No 5, May 2003)
This article reviews some of the basic provisions of the domestic asset protection trust legislation as enacted in Delaware and Nevada. It also analyzes how Florida courts may interpret the rights of the settlor’s creditors seeking to levy against the assets of a domestic asset protection trust, some of the common arguments suggesting that a domestic asset protection trust would be recognized by courts in other states, and some of the estate planning benefits of a domestic asset protection trust.

Domestic Asset Protection Trusts May 2003
Analysis of Asset Protection Plans for Physician Practice Groups
(The Florida Bar Journal, cialis usa buy Volume LXXVIII, pilule No. 3, March 2004)

This article reviews the goals of asset protection for Florida physician practice groups and analyzes the costs and benefits of four popular asset protection plans currently available to physician practice groups. This article also examines the potential fraudulent conveyance liability and corporate “claw-back” liability in connection with this type of planning. Finally, this article draws some conclusions as to the preferred method of asset protection planning for physician practice groups.

Analysis of Asset Protection Plans for Physician March 2004
Sale of Personal Goodwill – The Executive’s Parachute
(The Florida Bar Journal, cialis sale purchase
Volume 79, cialis generic No. 3, March 2005)

This article examines the sale of personal goodwill by defining it, reviewing pre-transaction methods to create and transfer it, analyzing the benefits of selling it, and explaining the tax treatment to the buyer in purchasing it.

Sale of Personal Goodwill March 2005
Achieving Capital Gains Treatment on Predevelopment Real Property Appreciation
(The Florida Bar Journal, generic viagra store Volume 80, cialis sales click No. 4, April 2006)

This article reviews the basic income taxation principles for real estate investors and developers, explains the mechanics of a “capital gains bailout” transaction for pre-development and post-development planning purposes, and highlights the income tax benefits derived from such a transaction.
Achieving Capital Gains Treatment April 2006
Asset Protection in the Partnership Context: What’s All the Hoopla?
(The Florida Bar Journal, cialis buy ampoule Volume LXVIII, treat No. 2, February 1994)
This article analyzes whether, under Florida law, property transferred to a partnership is actually protected from the claims of creditors of a general or limited partner. In addition, this article examines the various arguments which a partner’s creditor may use to levy against property owned by a partnership and whether a creditor should obtain a charging order or an assignment of the debtor partner’s interest in a partnership. Finally, this article explores the future status of transfers to partnerships to facilitate asset protection in light of the Revised Uniform Partnership Act.

Asset Protection in the Partnership Context Feb 1994
The New Limited Liability Company in Florida
(The Florida Bar Journal, viagra generic nurse Volume LXXIII, viagra generic look No. 7, July/August 1999)
This article summarizes the legislative process that resulted in the repeal of the Florida corporate income tax imposed on LLCs and to analyze some of the benefits and costs of the LLC compared with a limited partnership and a corporation electing Subchapter S status under the Internal Revenue Code of 1986, as amended.

The New Limited Liability Company in Florida – July-Aug 1999
Protecting Your Most Valuable Asset: Intellectual Property
(IT Professional, discount cialis view March/April 2001)

This article discusses a company’s abilities to protect intellectual property consisting of trademarks and service marks, sovaldi copyrights, malady patents and trade secrets, as well as the contractual protections that apply to employing IT staffers, consultants and subcontractors.

Protecting Your Most Valuable Asset – March-April 2001
Domestic Asset Protection Trusts – A Viable Estate and Wealth Preservation Alternative
(The Florida Bar Journal, viagra canada see Volume LXXVII, generic viagra No 5, May 2003)
This article reviews some of the basic provisions of the domestic asset protection trust legislation as enacted in Delaware and Nevada. It also analyzes how Florida courts may interpret the rights of the settlor’s creditors seeking to levy against the assets of a domestic asset protection trust, some of the common arguments suggesting that a domestic asset protection trust would be recognized by courts in other states, and some of the estate planning benefits of a domestic asset protection trust.

Domestic Asset Protection Trusts May 2003
Analysis of Asset Protection Plans for Physician Practice Groups
(The Florida Bar Journal, cialis usa buy Volume LXXVIII, pilule No. 3, March 2004)

This article reviews the goals of asset protection for Florida physician practice groups and analyzes the costs and benefits of four popular asset protection plans currently available to physician practice groups. This article also examines the potential fraudulent conveyance liability and corporate “claw-back” liability in connection with this type of planning. Finally, this article draws some conclusions as to the preferred method of asset protection planning for physician practice groups.

Analysis of Asset Protection Plans for Physician March 2004
Sale of Personal Goodwill – The Executive’s Parachute
(The Florida Bar Journal, cialis sale purchase
Volume 79, cialis generic No. 3, March 2005)

This article examines the sale of personal goodwill by defining it, reviewing pre-transaction methods to create and transfer it, analyzing the benefits of selling it, and explaining the tax treatment to the buyer in purchasing it.

Sale of Personal Goodwill March 2005
Achieving Capital Gains Treatment on Predevelopment Real Property Appreciation
(The Florida Bar Journal, generic viagra store Volume 80, cialis sales click No. 4, April 2006)

This article reviews the basic income taxation principles for real estate investors and developers, explains the mechanics of a “capital gains bailout” transaction for pre-development and post-development planning purposes, and highlights the income tax benefits derived from such a transaction.
Achieving Capital Gains Treatment April 2006
Asset Protection Proofing Your Limited Partnership or LLC for the Bankruptcy of a Partner or Member
(The Florida Bar Journal, buy viagra treat Volume 81, cialis canada drugstore No. 1 January 2007)

This article provides lawyers with an outline of asset protection benefits provided by an FLP, for sale analyzes how a bankruptcy proceeding by a partner in the FLP affects these protections, and suggests language to address the issues raised in In re Ehmann (Movitz v. Fiesta Investments, LLC), 310 B.R. 200 (Bank. D. Ariz. 2005).

Asset Protection Proofing Your Limited Partnership Jan 2007
Asset Protection in the Partnership Context: What’s All the Hoopla?
(The Florida Bar Journal, cialis buy ampoule Volume LXVIII, treat No. 2, February 1994)
This article analyzes whether, under Florida law, property transferred to a partnership is actually protected from the claims of creditors of a general or limited partner. In addition, this article examines the various arguments which a partner’s creditor may use to levy against property owned by a partnership and whether a creditor should obtain a charging order or an assignment of the debtor partner’s interest in a partnership. Finally, this article explores the future status of transfers to partnerships to facilitate asset protection in light of the Revised Uniform Partnership Act.

Asset Protection in the Partnership Context Feb 1994
The New Limited Liability Company in Florida
(The Florida Bar Journal, viagra generic nurse Volume LXXIII, viagra generic look No. 7, July/August 1999)
This article summarizes the legislative process that resulted in the repeal of the Florida corporate income tax imposed on LLCs and to analyze some of the benefits and costs of the LLC compared with a limited partnership and a corporation electing Subchapter S status under the Internal Revenue Code of 1986, as amended.

The New Limited Liability Company in Florida – July-Aug 1999
Protecting Your Most Valuable Asset: Intellectual Property
(IT Professional, discount cialis view March/April 2001)

This article discusses a company’s abilities to protect intellectual property consisting of trademarks and service marks, sovaldi copyrights, malady patents and trade secrets, as well as the contractual protections that apply to employing IT staffers, consultants and subcontractors.

Protecting Your Most Valuable Asset – March-April 2001
Domestic Asset Protection Trusts – A Viable Estate and Wealth Preservation Alternative
(The Florida Bar Journal, viagra canada see Volume LXXVII, generic viagra No 5, May 2003)
This article reviews some of the basic provisions of the domestic asset protection trust legislation as enacted in Delaware and Nevada. It also analyzes how Florida courts may interpret the rights of the settlor’s creditors seeking to levy against the assets of a domestic asset protection trust, some of the common arguments suggesting that a domestic asset protection trust would be recognized by courts in other states, and some of the estate planning benefits of a domestic asset protection trust.

Domestic Asset Protection Trusts May 2003
Analysis of Asset Protection Plans for Physician Practice Groups
(The Florida Bar Journal, cialis usa buy Volume LXXVIII, pilule No. 3, March 2004)

This article reviews the goals of asset protection for Florida physician practice groups and analyzes the costs and benefits of four popular asset protection plans currently available to physician practice groups. This article also examines the potential fraudulent conveyance liability and corporate “claw-back” liability in connection with this type of planning. Finally, this article draws some conclusions as to the preferred method of asset protection planning for physician practice groups.

Analysis of Asset Protection Plans for Physician March 2004
Sale of Personal Goodwill – The Executive’s Parachute
(The Florida Bar Journal, cialis sale purchase
Volume 79, cialis generic No. 3, March 2005)

This article examines the sale of personal goodwill by defining it, reviewing pre-transaction methods to create and transfer it, analyzing the benefits of selling it, and explaining the tax treatment to the buyer in purchasing it.

Sale of Personal Goodwill March 2005
Achieving Capital Gains Treatment on Predevelopment Real Property Appreciation
(The Florida Bar Journal, generic viagra store Volume 80, cialis sales click No. 4, April 2006)

This article reviews the basic income taxation principles for real estate investors and developers, explains the mechanics of a “capital gains bailout” transaction for pre-development and post-development planning purposes, and highlights the income tax benefits derived from such a transaction.
Achieving Capital Gains Treatment April 2006
Asset Protection Proofing Your Limited Partnership or LLC for the Bankruptcy of a Partner or Member
(The Florida Bar Journal, buy viagra treat Volume 81, cialis canada drugstore No. 1 January 2007)

This article provides lawyers with an outline of asset protection benefits provided by an FLP, for sale analyzes how a bankruptcy proceeding by a partner in the FLP affects these protections, and suggests language to address the issues raised in In re Ehmann (Movitz v. Fiesta Investments, LLC), 310 B.R. 200 (Bank. D. Ariz. 2005).

Asset Protection Proofing Your Limited Partnership Jan 2007
Profits Interest – Converting Compensation to Capital Gains and Other Planning Ideas
(The Florida Bar Journal, viagra generic cialis capsule Volume 81, cialis sale No. 11 December 2007)

This article focuses on an explanation of the tax treatment of a profits interest in structuring executive compensation packages by entrepreneurial ventures, in estate planning to transfer wealth to younger generations, as a bail-out from the double tax regime for potential appreciating property owned by a C corporation and as a restructuring of contingency fees for personal physician injuries.

Profits Interest Converting Compensation Dec 2007

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