Can anyone recommend a tax attorney?

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August 25, 2021

by a searcher from University of Colorado at Boulder in Los Angeles, CA, USA

Sole member LLC with negative retained earnings (has taken recourse debt over past few years, company has lost money) now wants to contribute LLC interests of company to a C Corp that will have other shareholders. What if anything can be done to minimize tax recapture?

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Reply by a professional
from New York University in New York, NY, USA
The recapture is just a recapture of the losses that the owners have taken. The owner could contribute capital in the amount of the losses, but other than that recognition will happen.
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Reply by a searcher
from University of Colorado at Boulder in Los Angeles, CA, USA
Thanks fellas - what about 351(a) workaround? Thought was to take advantage of 1202 w/ C Corp status if it makes sense, can avoid costly recapture.
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