Professional Experience
Andrew is a Partner and co-chairs FRB’s Taxation Practice Group. He advises clients on a wide range of federal and international tax matters, including deferral and characterization of income; partnership taxation; corporate taxation; and Opportunity Zones. He frequently represents closely held family businesses, real estate developers, and cannabis clients. He also has extensive experience in estate and gift tax planning.
Andrew’s articles on Opportunity Zones have appeared in Tax Notes, Bloomberg, California Tax Lawyer, and elsewhere. He is a frequent contributor to educational materials for California CEB (Continuing Education of the Bar) and has been quoted in the Wall Street Journal on the topic of foreign tax shelters.
Andrew started his career at the US Attorney’s Office in the Eastern District of California, prosecuting misdemeanors on federal land. He was also a federal judicial clerk and a staff attorney at the Ninth Circuit Court of Appeals. These government experiences inform his judgment in offering opinions on uncertain tax matters.
Education
- New York University School of Law – Master of Laws in Taxation
- New York University Stern School of Business – Certificate in Law & Business
- Columbia Law School – Juris Doctor
- Stanford University – Bachelor of Arts in History
Bar Admissions
- State of California
- State of Nevada
Professional Affiliations
- Volunteer, Bet Tzedek Low-Income Taxpayer Clinic, Los Angeles, California
- Certified Tax Specialist, California Board of Legal Specialization
Publications
Articles about Opportunity Zones have asterisks**.
- Journal of Taxation of Investments
- A Call for IRS Guidance on the Information Corporations Give Shareholders to Show That Stock Is QSBS. Forthcoming (Fall 2023).
- Tax Notes Federal
- **How Forgiving Recapture Gain Turns QOZs into Tax Shelters, (2019, November 25).
- **Incremental OZ Reform Could Be a Step Backward (letter to the editor), (2022, May 9).
- Tax Notes State
- **Opportunity Zone Planning When Penalties are a Certainty. (2022, July 11).
- ABA Tax Times
- Miranda Stewart, Tax and Government in the 21st Century: Book Review and Interview with the Author. With Jonathan Grossberg. 09/25/23.
- The Case For Letting Taxpayers Buy Ivermectin with Health Savings Accounts. 03/09/23.
- Bloomberg Insights
- Anonymous Letter to IRS Lays Out Defense of Malta Pension Plans. 9/11/23.
- Deferring Tax with IRC 453, Without Crossing the Line. 5/2/22.
- **Using a Qualified Opportunity Fund to Invest in non-QOZ Property. 03/15/22.
- Cannabis Taxpayers Find Flaws in New Section 471(c) Regs. With AB FinWright, LLP. 03/11/21
- Hidden Tax Dangers in Cannabis Outsourcing Arrangements. With AB FinWright, LLP. 09/15/21
- Bloomberg Tax Journals
- Negative Capital Freezes and Subchapter K. Real Estate Journal; Estate, Gifts, & Trusts Journal, 10/19/22.
- The Installment Method: Misuses that Make Me Lose Sleep. Real Estate Journal, 05/18/22.
- **What Good is OZ Reporting if We Don’t Agree on the Goals? Real Estate Journal, 03/16/22.
- Family Offices Allow (Some) Taxpayers to Deduct Investment Related Expenses. Estates, Gift, and Trusts Journal, 03/12/20. With Alan S. Gassman et al.
- California Tax Lawyer (Publication of the California Lawyers Association – Taxation Section)
- CEB Reporters
- QSBS Letters: Best (and Worst) Practices. Business Law Reporter. March 2022.
- Avoiding California Taxation: Considerations for Individuals Currently Domiciled in the State. Business Law Reporter. July 2021.
- Trustee’s Personal Liability for Estate Taxes. Estate Planning & California Probate Reporter. November 2021.
- Real Estate Tax Tips During Coronavirus. Real Property Law Reporter. May 2020.
- Coronavirus Legislation Contains Employment Tax Relief, and Mixed Messages. Business Law Reporter. July 2020.
- California Taxation (Sep. 2020) Case Summary. 42 Cal. Bus. L. Rep. 2
- LA Daily Journal
- If you squander this once-in-a-lifetime chance to make tax-free gifts, you’re not a bad person. 11/02/21.
- **QOZ projects have ‘up to’ 24 more months due to COVID-19. 03/19/20. With Michael Wiener.
- **Treasury Releases Long-Awaited QOZ Regulations. 04/19/19. With Neda Barkhordar.
- Should You Change Your Accounting Method? An Emerging Cannabis Loophole. With AB FinWright, LLP. 06/16/20
- Quoted in
- Wall Street Journal, IRS Says Tax-Free Maltese Pensions Are Too Good to Be True. 12/21/21.
- Journal of Taxation, Shop Talk: How Small Can a Partner’s Interest Be: Did “Small” Just Get Smaller? Publication Pending. By Sheldon I. Banoff, Richard M. Lipton, and Adam M. Cohen.
- Your Tax Matters Partner blog
- CEB (CA Continuing Education of the Bar) blog
- **IRS Releases Generous Guidance for QOZs During Coronavirus Pandemic.
- **Poking Holes in the Final QOZ Regulations. 01/30/20.
- Limits on the Installment Method of Accounting for Gain. 10/15/20.
- California Passes Partial Tax Conformity Bill, Raising More Questions. 10/17/19.
- Split Roll Ballot Measure Could Scale Back Proposition 13. 10/01/20
- Employment Tax Relief Under the Families First and CARES Acts. 05/06/20
- 420cpa.com blog
- The Mechanics of the Cannabis Cultivation Tax in California. 07/24/20. With Abraham Finberg & Rachel Wright.