Maintenance of 704(b) capital accounts, including but not limited to:

• Shifting equity, and preventing equity shifts through maintenance of 704(b) capital accounts;
• Analyzing fair market value for book-ups/downs on contribution (704(c)) and subsequent transactions (reverse 704(c));
• Analyzing operating agreements and allocations thereto for substantial economic effect;
• Reviewing and revising thousands of partnership agreements for state law issues, as well as, federal income tax issues;
• Assisting with allocation of tax credits to the given party through partnership agreements;
• Drafting profits interest and capital interest into partnership agreements, as well as drafting layered allocations for each type of interest;
• Drafting internal rate of return into layered allocations;
• Revising partnership agreements to comply with how the accounting has been handled; and
• Outlined all 704(b) regulations and structured thousands of transactions based on such outlines and use of other sources.