Stuart J. Gross, for more than 25 years, has concentrated on estate planning and the taxation of real estate transactions. Using an approach that integrates business, tax, and estate planning objectives, he counsels individuals and family groups with hundreds of millions of dollars of assets, applying his extensive experience in the partnership, real estate and financial products areas to accomplish inter-generational transfers in the most tax-efficient fashion. Representing closely held owners and developers, he has structured real estate developments, equity leases, loan workouts on troubled properties, and securitized financings, including the management of interest-rate risk and currency hedges. His in-depth knowledge of the rules governing the taxation of partnerships and LLCs has been particularly valuable in property transfers involving such diverse areas as UPREITs and family business restructurings. With the enactment of special valuation rules for family-owned entities that link estate and gift tax concepts with income tax concepts, his expertise in both areas provides for seamless and effective representation of clients. He has also worked extensively with all different types of hedge funds and their managers on a broad range of tax issues. He has focused on innovative uses of financial products for the funds, including straddle, hedging and holding period issues. He has created tax-efficient structures for the management of hedge funds to achieve a deferral of management fee income, a reduction in required capital contributions by the manager, beneficial allocations of different classes of income, and a transfer of value to younger-generation family members for estate planning purposes. He advises clients on the use of private foundations, including charitable contribution and self-dealing issues. He also has negotiated on behalf of his clients major agreements with charitable organizations. He has served the Tax Section of the NY State Bar Association as Chairman of the Committee on Individuals, and Chairman of the Committee on Tax Preferences and AMT.
He graduated magna cum laude from Yale and received his J.D. cum laude from Harvard.
Published: Estate & Gift Tax Planning Newsletter, August, 2016