Your Questions Answered: Everything You Want to Know About Qualified Small Business Stock

Scott A. Bowman’s practice focuses on providing personal tax and estate planning counseling to wealthy individuals and families, advising them on structuring their wealth to minimize income, estate, gift and generation-skipping transfer taxes over multiple generations. He advises on trustee and family governance structures throughout the estate and trust administration process to preserve business enterprises and manage potentially sensitive family circumstances.

Scott is experienced in handling international aspects of tax and estate planning for multi-national families, advising non-US citizens who are considering immigrating to the United States, investing into US financial and real estate markets or transferring wealth to US beneficiaries by gift or inheritance. Scott also advises US clients living or investing abroad and with regard to US expatriation.

Michael J. Bruno advises multinational companies, funds, single family offices, and entrepreneurs on sophisticated US and international tax planning and transactions. He has extensive experience in advising clients in the technology, healthcare, life sciences, digital health, consumer products, FinTech and cryptocurrency, and sports and entertainment industries.

Michael regularly advises clients on mergers, acquisitions, restructurings, joint ventures, and divestitures in various business contexts. He has assisted clients with many international tax issues, including navigating anti-deferral (controlled foreign corporation (CFC) and passive foreign investment company) regimes, foreign tax credit planning, export planning, treaty planning, intellectual property migrations, tax-efficient cash repatriation strategies, and post-acquisition integration and implementation.

Michael also regularly advises entrepreneurial families on strategies for minimizing US income taxation with respect to their closely held businesses and investments, including qualified small business stock planning. Through comments and a presentation, Michael advocated on behalf of The Florida Bar Tax Section for Congress, the Internal Revenue Service, and the US Department of the Treasury to afford the Section 250 deduction to electing Section 962 shareholders that earn Global Intangible Low-Taxed Income, as well as reinstating the repeal of Section 958(b)(4) for CFC downward attribution.

He has written numerous articles on international tax planning and frequently submits comments on statutory and regulatory promulgations. As a strong proponent for pro bono legal services, Michael founded the Transactional Equal Justice Program with Legal Services of Greater Miami, which offers free legal advice to nonprofits and low-to-moderate income small business owners to help them launch a business.

Katrina (Katy) Crafton Fluet advises ultra-high-net-worth individuals, families and charities on all aspects of federal and state estate, gift and generation-skipping transfer tax matters, charitable planning, estate and trust administration and succession planning for closely-held companies. Katy frequently counsels clients on the structure and implementation of complex, leveraged wealth-transfer techniques, often with a focus on state income tax planning. In addition, she has extensive experience in planning for qualified small business stock (QSBS) and cryptocurrency.

Katy currently serves as the Hiring Partner for the Silicon Valley and San Francisco Offices, and participates in McDermott’s Diversity & Inclusion and Pro Bono & Community Service committees. In addition, she currently serves on the California Lawyers Association’s Trusts and Estates Executive Committee.

Katy has lectured to regional and national audiences on a broad variety of topics in estate planning, tax reporting, the effect of spousal rights for property law and tax purposes and the impact of state legislation specific to same sex couples for federal and state transfer and income tax purposes. Katy was a recipient of the Firm’s Pro Bono and Community Service Award in 2010.

While in law school, Katy was an editor of The Elder Law Journal and a Harno Scholar.

Steven Hadjilogiou focuses his practice on tax optimization of business operations and investments with a specific emphasis in the areas of international tax and real estate. Steven provides advice on international inbound and outbound tax planning for multinational companies, family offices, private equity and ultra-high net worth individuals. He also advises funds, family offices and ultra-high net worth individuals in connection with complex real estate structuring and investment issues, including in the areas of opportunity zone funds, 1031 transactions and qualified small business stock.

Steven has represented various Fortune 500 companies and major privately held businesses in their tax planning and supply chain projects, and also has substantial experience advising on transfer pricing, tax-related intellectual property matters, Subpart F, GILTI, foreign investment in US real property and outbound investment in real property. Steven also advises clients on pre-immigration planning and cross-border wealth succession. Steven has also worked on the taxation of partnerships and corporations, mergers & acquisitions and international corporate reorganizations.

Since 2013, Steven has been an adjunct professor of International Inbound Taxation at the University of Miami Graduate Tax Program. He is the co-chair of the annual Florida Bar/FICPA International Tax Conference. Steven has written numerous articles and presented on topics related to tax. He was a primary drafter of the amicus curiae brief submitted to the US Supreme Court on behalf of the Florida Bar Tax Section in Knight v. Commissioner in 2008.