Professional Experience
Andrew is Of Counsel in 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
- Avoiding California Taxation: Considerations for Individuals Currently Domiciled in the State, Business Law Reporter, (2021, July).
- California Taxation (Sep. 2020) Case Summary, 42 Cal. Bus. L. Rep. 2, (2020, September).
- Cannabis Taxpayers Find Flaws in New Section 471(c) Regs, (2021, March 11). With AB FinWright, LLP.
- Coronavirus Legislation Contains Employment Tax Relief, and Mixed Messages, Business Law Reporter, (2020, July).
- Deferring Tax with IRC 453, Without Crossing the Line, (2022, May 2).
- Family Offices Allow (Some) Taxpayers to Deduct Investment Related Expenses, Estates, Gift, and Trusts Journal, (2020, March 12). With Alan S. Gassman et al.
- Hidden Tax Dangers in Cannabis Outsourcing Arrangements, (2021, September 15). With AB FinWright, LLP.
- 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).
- The Installment Method: Misuses that Make Me Lose Sleep, Real Estate Journal, (2022, May 18).
- Negative Capital Freezes and Subchapter K, Real Estate Journal; Estate, Gifts, & Trusts Journal, (2022, October 19).
- Opportunity Zone Planning When Penalties are a Certainty, (2022, July 11).
- Personal Goodwill For New QO Funds, Business Goodwill For Old Ones: IRS May Cry “Whipsaw”, (2022, February).
- QSBS Letters: Best (and Worst) Practices, Business Law Reporter, (2022, March).
- Real Estate Tax Tips During Coronavirus, Real Property Law Reporter, (2020, May).
- Trustee’s Personal Liability for Estate Taxes, Estate Planning & California Probate Reporter, (2021, November).
- Using a Qualified Opportunity Fund to Invest in non-QOZ Property, (2022, March 15).
- What Good is OZ Reporting if We Don’t Agree on the Goals?, Real Estate Journal, (2022, March 16).