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 books 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;