Michael LaBriola |

LaBriola Tax & Estate Planning

Michael LaBriola | LaBriola Tax & Estate Planning

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Firm Summary

Michael V. LaBriola, formerly of counsel at Greenberg Traurig, LLP, concentrates his practice on complex and sophisticated estate and income tax planning for domestic and international high-net-worth individuals and their families. He has wide-ranging experience in achieving multi-generational wealth preservation and accumulation, as well as probate and trust administration. Michael also frequently implements business succession and transition planning for privately held companies, business owners and entrepreneurs to build and preserve the value of their companies and personal net worth.

In the course of structuring plans to transfer wealth in the most tax-efficient manner possible, Michael encourages his clients to consider the non-tax implications their planning will have on their families and business partners.

Michael also acts as corporate counsel to numerous private companies, advising them on a wide range of business matters, from entity formation and structuring to sale of the company to third party buyers and outside investors.

Areas of Concentration

• Multi-generational wealth preservation and tax planning
• Sophisticated estate planning, life insurance planning and funding strategies
• Business and succession planning
• Charitable planning giving
• Estate and trust administration
• Probate matters and complex post-mortem tax planning
• Captive insurance companies
• Installment sales to Intentionally Defective Grantor Trusts
• Grantor Retained Annuity Trusts (GRATs)
• Qualified Personal Residence Trusts (QPRTs)
• Irrevocable Life Insurance Trusts (ILITs)
• S corporations
• Limited liability companies (LLCs) and limited partnerships
• Property tax and real estate tax issues

Professional & Community Involvement

• Board Member, Juvenile Diabetes Research Foundation of Orange County
• Member, Orange County Bar Association, Tax and Trusts & Estates Section

Awards & Recognition

• Listed, Super Lawyers Magazine, Southern California Super Lawyers, “Rising Star,” 2013 and 2014.  Only 2.5% of the attorneys under age 40 in Southern California are selected for this honor.

Education

LL.M., With High Distinction, Loyola Law School, Los Angeles, 2004

• First Honors Award, Partnership Tax I
• First Honors Award, Corporate Tax II
• First Honors Award, Income Tax III (Property)

J.D., Loyola Law School, Los Angeles, 2000

• Senior Note & Comment Editor and Staff Writer, International & Comparative Law Review
• Dean’s Honor List
• First Honors Award, Sports Law

B.A., Columbia University, 1996

• Dean’s List
• Men’s Basketball
• Columbia College Young Alumni Association

Significant Representations

• Structured sale of business entity valued at $9 million to an intentionally defective grantor trust for the benefit of the business owner’s children in return for a self-cancelling installment note.
• Arranged acquisition of $30 million life insurance policy by an irrevocable life insurance trust (ILIT) via a split dollar agreement.
• Structured sale of real estate entity valued at $30 million via a private annuity to an intentionally defective grantor trust for the benefit of the business owner’s children.
• Advised client on tax implications of $30 million purchase where property was held subject to a tenancy-in-common arrangement.
• Advised client on purchase of $10 million commercial real property in a transaction that qualified as a tax deferred “1031 like-kind exchange.”
• Merged 15 California securities limited partnerships valued in excess of $250 million into two Delaware series securities limited partnerships in tax-free roll-up.
• Advised client on the tax implications of unwinding complex partnership and trust structure in order to recover more than $20 million of misappropriated funds.
• Represented client seeking “innocent spouse” relief in Tax Court, and such was granted.

Internship

• Congressional Legislative Intern, U.S. Congress, 46th District Office, Garden Grove, California, 1995-1996

Articles, Lectures & Publications

• Author, “The New Tax Act Benefits,” Orange County Business Journal, February 2011
• Co-Author, “Estate Planning in 2010 and 2011: Navigating Without a Compass,” Orange County Business Journal, September 2010
• Co-Author, “Defensive Tax Planning Strategies,” Orange County Business Journal, September 2009
• Author, “Tax Consequences of Accepting Warrants in Loan Transactions,” Orange County Business Journal, August 2008
• Author, “Protecting S Corporation Assets from Business Liabilities,” Orange County Business Journal, September 2008

Admitted to Practice

• California
• U.S. Tax Court