Richard concentrates his practice in providing thorough, sophisticated and creative income tax planning for entrepreneurs in connection with their business operations. This advice encompasses the type of entity clients should use to operate their business, restructuring of business entities to reflect ownership changes or changes in business operations, acquisition or sales of business entities, and the liquation of the business entity. Richard's goal is to develop, in close consultation with clients, tax strategies that will minimize the tax costs of engaging in a particular transaction and effectuating a client's business plan that will be respected if reviewed by the Internal Revenue Service or state taxing authority. Richard has over 25 years of experience in dealing with partnership, corporate, S Corporation, foreign and general tax matters and issues. His experience is complemented by his legal training which includes a Master of Laws in Taxation he received from NYU in 1983.
Richard has extensive experience in representing clients before the IRS and the Connecticut Department of Revenue Services. He has successfully defended clients against IRS audits seeking to impose significant deficiencies or to enforce tax liens and he successfully undertaken to settle taxes owed by clients by negotiating an "Offer In Compromise" with the IRS. Richard has also successfully pursued refund claims with the IRS and the Connecticut Department of Revenue Services.
Another import aspect of Richard's practice is estate planning for his entrepreneurial clients. His unique ability to combine his knowledge of his clients' business operations and income tax considerations with his clients' long term estate planning objectives enables him to achieve the clients' goals with the best overall gift, estate and income tax results. Richard's experience as an IRS Estate and Gift Tax Attorney gives him valuable insight and experience in dealing with estate and gift tax issues.
Richard joined the law firm of Trager & Trager, P.C., as an associate in 1988. In 1999 when Trager & Trager merged into Berkowitz, Trager & Trager, LLC, Richard became a member of the firm. Richard was an associate at the firm of Carmody and Torrence (1987-1988), and was an Estate & Gift Tax Attorney with the Internal Revenue Service, Manhattan District (2005-2007).
- New York University, LLM, Taxation, 1983
- California Western School of Law, J.D., 1981
- State University of New York at Albany, B.A., 1977
- State of California, 1981
- State of Connecticut, 1988
- Representation of client in conjunction with $500,000,000 acquisition and restructuring of company having operations in both the United States and Canada.
- Representation of developer in structuring sale of property rights having a value in excess of $50,000,000.
- Representation of corporation having assets in excess of $100,000,000 in restructuring of ownership involving foreign nationals to enable corporation to make "S" Election for income tax purposes and receive flow through tax treatment and avoid corporate tax..
- Representation of client in successfully reversing IRS audit determination that would have imposed in excess of $10,000,000 of taxes, interests and penalties.
- Representation of client engaged in like-kind exchange of air craft having values in excess of $50,000,000.
- Representation of developer seeking to structure business operations to consolidate many limited liability companies into one holding company.
- Representation of company with business operations in many States regarding state and local tax issues.
- Representation of a developer in entering into a partnership with investors to acquire approximately $8,000,000 of solar equipment eligible for the energy tax credit allocable to the investors.