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Truth and Consequences: Understanding Section 704(c) Demystified
LIVE Webcast
Noel Brock
Partner, Partnership Technical Tax Practice Leader
Grant Thornton LLP
Noel Brock is a partner and the Partnership Technical Tax Practice Leader in the National Tax Office of Grant Thornton LLP. He practices in all area of partnership taxation and assists the offices around the firm and the firm’s external clients with complex partnership issues. He regularly advises on issues relating to domestic and international partnership and joint venture structuring, financing, formation, allocations and distributions, private equity and venture capital funds and other partnership matters.
Prior to joining Grant Thornton LLP in 2008, Noel spent over 12 years in private practice at the National office of an international accounting firm and at international law firms in which he advised clients in several areas of tax law, including partnership, international, corporate and financial products.
Noel is a former Lecturer in Law at the Catholic University of America, Columbus School of Law, where he taught classes in both partnership and corporate taxation. He is currently an adjunct faculty member at George Mason University’s School of Law and at American University’s Washington College of Law.
Education: LL.M. (Tax), Georgetown Univ. Law Center; J.D., West Virginia University College of Law, Order of the Coif and Editor-in-Chief of the West Virginia Law Review; Master of Professional Accountancy, West Virginia University College of Business and Economics; B.S. in Business Administration (Concentration Accounting), Concord College
Mr. Brock has spoken at national and regional tax conferences, including the ABA and the DC Bar. He also has authored and co-authored articles in national journals on corporate and partnership tax issues. His work has been cited by other leading tax professionals and in major treatises.
George E. Spaeth
Managing Director, Washington National Tax
KPMG LLP
George Spaeth is a Managing Director in the Partnership and Passthrough group of KPMG LLP’s Washington National Tax (WNT) practice, where he assists the firm’s local offices with partnership and S corporation projects. He has dedicated a considerable portion of his time at WNT to both internal and external training. He has co-instructed for a Tax Executives Institute regional event and has also co-instructed a number of webinar programs for CCH and Strafford Publishing, including a recent presentation entitled, “Internal Revenue Code Section 704(c) Partnership and LLC Contributions.” In 2009, he co-authored “Form 1065: Preparing for the New Year’s Changes” published in the Journal of Passthrough Entities.
Mr. Spaeth was also an Adjunct Professor of Taxation at the Indiana University (Indianapolis) Kelley School of Business where he taught “Individual Income Tax” for seven years.
Brian Knudson
Partner
Ernst & Young, LLP
Brian Knudson is a partner in the Partnership and Joint Venture Group of the National Tax Department of Ernst & Young and is resident in the Minneapolis office. Brian has worked extensively with very large and complicated joint venture structures, often involving large multi-national corporate partners, in accounting for various partnership matters, including workouts and bankruptcies. Brian is a graduate of the University of St. Thomas (B.A. in accounting, 1991). He is a member of the American Institute of Certified Public Accountants and the Minnesota Society of Certified Public Accountants. Brian is also an adjunct professor in the masters in taxation program at the Curtis L. Carlson School of Management at the University of Minnesota, where he teaches a course covering advanced topics involving the taxation of partnerships.
John D. Currivan
Partner
Jones Day
John Currivan has wide experience in the taxation of partnerships and limited liability companies, including a variety of venture capital transactions, private equity fund formation, corporate joint ventures, partnership acquisitions and dispositions, and complex restructurings of debt and equity interests. He also has substantial experience in tax-free exchanges involving real estate and personal property. John is coordinator of the Tax Practice in the Firm's Cleveland Office.
John provided the principal advice on partnership debt and equity restructuring in the bankruptcy of Chrysler. Transactions in which John was the principal advisor on partnership tax matters include the formation of joint ventures between Micron and Intel, between Goodrich and Rolls Royce, and between T-Mobile and Cingular. John provides tax advice to a variety of private equity and venture capital funds, including Riverside, Key Principal Partners, Morgenthaler, and Primus.
John is co-author of the BNA Portfolio "Corporate Bankruptcy." He is also co-author of a book on Ohio limited liability companies and the principal author of an article on contingent obligations in partnerships. John is a frequent speaker at the Cleveland Tax Institute, has chaired the Institute, and currently serves on its Executive Committee. He also has been a speaker at the Tax Executives Institute. John has been an adjunct professor at Case Law School, teaching advanced partnership taxation. He is a member of the ABA's Section of Taxation and its Subsection of Partnerships and LLCs.
Truth and Consequences: Understanding Section 704(c) Demystified
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