Attorney

H. Jacob Lager, Partner

Chair - Business Transactions and Tax

310.255.6193 |   310.255.6293 |   jacob.lager@ffslaw.com
Download vCard | Office: Century City

H. Jacob LagerH. Jacob Lager is Chairman of the Business Transactions and Tax Department. His practice is concentrated in domestic tax, international taxation, and trust and estate matters.

Extensive experience in domestic tax matters

Mr. Lager possesses extensive experience in the structuring of business transactions, and advising domestic and cross-border clients on tax implications related to corporate mergers, asset acquisitions, spin-offs, and debt exchanges. He routinely drafts information disclosures for proxy statements, public filings, and private offerings. Mr. Lager also advises clients regarding the inception and maintenance of special status entities such as S corporations, disregarded limited liability companies, partnerships, REITS, and tax-exempt charitable organizations. He has advocated for clients at all levels of tax dispute resolution. Mr. Lager also has been involved with the tax implications of corporate dissolutions, partnership and corporate redemptions and reorganizations, mergers, buy-outs, transition agreements, succession planning and other capital events that often result from the resolution of co-owner disputes.

International practice

Mr. Lager has developed specific experience in tax implications of cross-border matters, which often encompasses the U.S. treatment of domestically held foreign interests. He counsels clients on Tax Treaty benefits and corresponding withholding obligations related to international loan agreements, royalty arrangements and dividend payments. Mr. Lager frequently assists non-U.S. clients in making tax-efficient investments within a variety of U.S.-based companies.

Trust and estate planning

In addition, Mr. Lager provides estate planning services to high net-worth individuals related to estate taxation, generation-skipping taxation, fiduciary income tax, and post-mortem tax and succession planning. He has experience in probate and private trust administration, from living trusts to more involved GRATs, QPRTs, family limited partnerships and LLCs, ILITs, charitable trusts, and other manners of deferred giving. He also advises his foreign clients who want to make cross-generational gifts to U.S. heirs.

Honors

Mr. Lager has been selected by his peers for inclusion in the 2019 and 2020 editions of Best Lawyers in America® in the field of Trusts and Estates.

Attorney Education

EDUCATION

J.D., University of Pennsylvania Law School

B.A., University of California at Berkeley

Attorney Admited to Practice

California
U.S. District Court for the Central District of California
U.S. Court of Appeals for the Ninth Circuit
U.S. Tax Court

Representative Clients and Matters

Defended a foreign professional athlete against an asserted tax determination based on alleged in-state residency.

Navigated tax treaty networks to structure a multi-national licensor of software across three continents and a dozen countries.

Defended a large family trust against a transferee liability assessment for estate taxes due from a related estate.

Guided “accidental” US citizens and other inadvertent delinquent FBAR filers through IRS compliance procedures, including the Service’s OVDP and Streamlined processes.

Professional & Community Involvement

Los Angeles County Bar Association

Bet Tzedek New Leadership Council | Chair | 2008 – 2011

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