Chris is an attorney and a CPA with a focus on tax and estate planning. His law practice includes drafting wills and trusts; advising on income, gift, estate, and GST tax issues; forming business and nonprofit entities; and probating estates. Chris is experienced in the preparation of gift and estate tax returns, representation of executors in all phases of estate administration, and creating comprehensive estate plans tailored to meet clients' personal objectives in a tax efficient manner.
Chris’ business planning practice includes counseling clients with respect to the establishment, reorganization, operation and tax reporting requirements of their business and related transactions. A primary emphasis of business planning is placed on the transfer of business interests to family members in the most tax efficient manner thereby providing the second (or third) generation with the best chance of family business continuance.
Chris is a Certified Public Accountant, licensed in Texas and Florida. Prior to law school, he worked in the tax department of a major public accounting firm in West Palm Beach, FL.
Chris was admitted to practice in Texas in 2016 and in Florida in 2015.
- University of Florida Levin College of Law Graduate Tax Program, LL.M. in Taxation, 2016
- Graduate Assistant, Professor Dennis Calfee
- Winner of the Bloomberg Law Write-On Competition (published in BNA Daily Tax Report)
- University of Florida Levin College of Law, J.D., 2015
- Order of the Coif (top 10% of graduating class)
- Florida Law Review, Managing Editor
- Estate Planning Certificate
- Research Assistant, Professor Lee-Ford Tritt
- Florida Tax Moot Court, President
- Volunteer Income Tax Assistance (VITA) Program, President
- Book Awards (for highest grade in the following courses): Income Taxation, Corporate Taxation, Partnership Taxation, Taxation of Gratuitous Transfers, Advanced Estates & Trusts, and Tax Moot Court
- Winner of the Tax Analysts Student Paper Competition (published in Tax Notes)
- Second Place, ACTEC Student Writing Competition
- Runner Up, Federal Bar Association Tax Law Writing Competition (published in Inside Basis)
- Florida Atlantic University, M.S. Taxation, 2010
- University of Florida, B.S., Accounting, 2009
- State Bar of Texas
- State Bar of Florida
- American Bar Association
- Real Property, Trust & Estate Law Section
- Taxation Section
- Texas Bar Association
- Real Estate, Probate and Trust Law
- Tax Section
- Dallas Bar Association
- Probate, Trusts & Estates Section
- Tax Section
- Dallas Association of Young Lawyers
- Florida Bar Association
- Real Property, Probate Law
- Tax Section
- Young Lawyers
- Out-of-State Division
- Texas Society of Certified Public Accountants
- Dallas CPA Society
- Comerica Tower Toastmasters
- “Choice of Entity and Self-Employment Tax,” Dallas Bar Association (DBA) Headnotes, December 2017
- "Community and Separate Property Regimes: Educating the Mobile Client and the Multijurisdictional Attorney," State-to-State Newsletter published by The Florida Bar Out-of-State Division (Summer 2017)
- "The Private Trust Company: A DIY for the Uber Wealthy," 52 ABA Real Property, Trust and Estate Law Journal 121 (Spring 2017)
- "Deducting False Claims Act Settlements: The Silver Lining to the Whistleblower Cloud," BNA Daily Tax Report, Issue No. 64 (April 2016)
- "Intervention in the Tax Court and the Appellate Review of Tax Court Procedural Decisions," 67 Florida Law Review 1483 (2015) (co-author)
- "How Do You Want Your Eggs: Taxed or Nontaxed?," 145 Tax Notes 81 (2014)
- "Starting with the [Tax] Man in the Mirror: Asking the IRS to Change Its Ways of Valuing Postmortem Publicity Rights," Inside Basis (Federal Bar Association Section on Taxation Summer 2014)
As Year-End Approaches, Donations of Bitcoin and Other Virtual Currencies Explained... [ read ]
Time is running out to make charitable contributions for the 2017 tax year. With virtual currencies trading at record highs, contributions of this pioneering property may be a viable option for some. The most common (and valuable) virtual currency is Bitcoin, which is valued at approximately $9,600 as of this writing and up over 900% year-to-date. Other popular virtual currencies include Etherum (valued at approximately $415) and Bitcoin Cash, a split-off of Bitcoin (valued at $1,260). For those riding the Bitcoin rocket ship (or, perhaps, the Bitcoin roller coaster), you may consider taking advantage of the following favorable charitable contribution tax rules.
Treasury and IRS to Withdraw Controversial 2704 Proposed Regulations... [ read ]
The long, tumultuous road of the proposed regulations under I.R.C. Section 2704 (the "2704 Proposed Regulations") should be coming to an end with Treasury's recent report in response to Executive Order 13789.
Section 2704 Proposed Regulations Identified for Burden Reduction in IRS Report... [ read ]
I last provided an update on the proposed regulations under I.R.C. Section 2704 (the 2704 Proposed Regulations) on January 31, 2017, in which I covered President Trump's then recent Executive Orders and their potential to halt to the controversial 2704 Proposed Regulations. Since then, President Trump has called on the Treasury to identify burdensome tax regulations, and the fate of the 2704 Proposed Regulations (at least under the Trump administration) may be known as soon as September.
Community and Separate Property Regimes: Educating the Mobile Client and the Multijurisdictional Attorney... [ read ]
Most clients and many attorneys are unfamiliar with the concept of community property-that is, how it works and how it affects a broad spectrum of legal practices including family law, tax law and estate planning. For attorneys with diverse clients and multijurisdictional practices, ignorance of community property law can be costly. This article provides an introduction to the community property system and highlights topics to discuss with clients planning a move either to or from a community property state.
An Update on the Uncertain Fate of the Proposed Section 2704 Regulations... [ read ]
Before they were released in August of last year, we all knew the proposed regulations under section 2704 were going to be controversial. What we didn't know back then was that Donald Trump was going to be president. With the new administration, the section 2704 regulations project could be altogether abandoned. And even if finalized, the Republican controlled Congress could severely undermine the impact of the regulations with a major tax overhaul, including a possible repeal of the estate tax. Despite this uncertainty, Treasury has provided some good news, hinting at the addition of a closely-held business exception to the regulations.
Investment Through Foreign-Owned Entities Just Got More Burdensome... [ read ]
Beginning January 1, 2017, foreign-owned single member LLCs—disregarded entities commonly used to invest in U.S. real estate—will have increased reporting and record keeping requirements.
Tax Do-Overs: Unwinding a Transaction under the Rescission Doctrine... [ read ]
Growing up my Mom used to say "You've made your bed, now lie in it." Luckily for taxpayers, my Mom is not the IRS. The IRS understands that mistakes happen, conditions change, and deals sour. Under the rescission doctrine, a taxpayer may unwind a transaction and avoid federal income tax consequences flowing from the rescinded transaction.
Congress Takes Aim at the Proposed 2704 Regulations... [ read ]
As I discussed in detail in my August 4, 2016 blog post, the new proposed regulations are undoubtedly controversial. In their current form, they disregard longstanding valuation principles backed by decades-old legal precedent, and, in doing so, virtually eliminate minority and lack of marketability discounts. To no surprise, the regulations have come under fire from family business owners, tax practitioners, and appraisers, who criticize the new rules as regulatory overreach and the Treasury's attempt to change and make law.
Without Further Ado, The Proposed Regulations Under Section 2704... [ read ]
Two days ago, the Treasury released the much-awaited proposed regulations under § 2704. If finalized in their current form, they will likely drastically change the landscape of estate planning with family controlled entities by severely curtailing (if not eliminating) minority and marketability discounts largely predicated on liquidation restrictions. Some of the major changes include the closing of perceived loop holes in § 2704's definition of applicable restrictions; namely, state law restrictions, assignee interests, and interests held by nonfamily members.