Margaret S. Ng

Estate Planning and Administration

• Represented families in structuring gift transfers of two-class partnerships with preferred and carried interests (in accordance with IRC Section 2701).
• Represented founders and business owners in estate tax and federal and state income tax planning in preparation of company and stock sales (including qualified small business stock tax planning).
• Represented founders, business owners, and retirees in connection with California tax domicile exit planning.
• Represented families in forming charitable remainder and charitable lead trusts.
• Represented U.S. beneficiaries in the buyout of their interests in a billion-dollar estate.
• Represented non-resident and cross-border families to structure with wealth transfers for the benefit of U.S. beneficiaries.

Family Office and Fund Formation

• Represented various fund sponsors in connection with negotiating and preparing partnership and LLC agreements for operating and investment vehicles.
• Restructured family office ownership structure after death of first-generation principal to reduce capital gains on their real estate portfolio.
• Acted as lead tax counsel to sponsors of solar energy tax equity partnerships in connection with various capital raises.
• Represented family office to structure separation of partners in a manner to avoid a real property tax reassessment.
• Advised institutional investors of an agricultural fund on possible unrelated business taxable income and debt-financed income.

Real Estate Tax Matters

• Successfully appealed a new construction property tax assessment of a multi-story parking facility, reducing the assessment from $64 million to $35 million.
• Represented a majority investor to negotiate tenants-in-common documentation for a $61 million investment in Atlanta, Georgia.
• Represented a publicly held multinational company and successfully challenged the reassessment of its Huntington Beach plant arising from a synthetic lease transaction, reversing the reassessed value of $39 million to the original assessed value of $19 million.
• Challenged the reassessment of a 93-unit apartment complex in San Diego County arising from a non-pro rata trust distribution, reducing the reassessed value from $21 million to $12.5 million.
• Challenged the reassessment of a leasehold interest in Los Angeles County resulting from the recordation of a ground sublease assignment, reversing the reassessed value of $24.6 million to the original assessed value of $7.9 million.
• Advised client on the tax implications of the condemnation of a $52 million high-rise office building in connection with the Los Angeles County purple line subway extension.

"So Long, Step-up Rule?," Barron's Magazine (September 2021)