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- Lucien A. Beaudry
Lucien A. Beaudry is a shareholder in Reinhart’s Tax and Corporate Law practices, chair of the Federal Tax Planning and Executive Compensation teams, and a member of the Tax-Exempt Organizations and Hospice teams. Lucien works with a wide range of clients and industries including public companies, private equity and venture capital firms, family businesses and tax-exempt organizations. He is also a frequent speaker, author and an active volunteer in the community.
As a licensed and certified public accountant, Lucien brings a unique financial understanding and business sensibility when advising clients. He understands the importance of “boiling down” complex rules so that his clients may make well-informed, practical business decisions.
Lucien serves as a trusted adviser and confidant to his clients. He takes ownership of his client’s issues and works to design practical solutions and capitalize on available opportunities. Lucien has also successfully developed and implemented creative approaches to resolve difficult, challenging and contentious matters.
In addition to his legal practice, Lucien is a frequent speaker on a variety of tax and business law topics. He also teaches the “Partnerships, LLCs and S Corporations” class in the Master of Taxation Program at the University of Wisconsin-Milwaukee. Lucien is a graduate of Leadership Milwaukee and an active volunteer in the community.
Education
- J.D., cum laude, University of Wisconsin Law School
- B.S., magna cum laude, University of Wisconsin-Milwaukee
Bar Admissions
Wisconsin
Court Admissions
- Milwaukee Bar Association
Successfully obtained several IRS private letter rulings, saving the clients significant federal and state income taxes. Examples include:
PLR 200326007: The IRS granted an extension of time to make a Qsub election, which resulted in significant savings of the "passive investment income tax" and allowed the client to maintain its S corporation status.
PLR 200527002: The IRS granted "inadvertent termination" relief to an S corporation that had transferred stock to an ineligible shareholder.
PLR 200606008: The IRS granted an extension of time to make a "check the box" election for a foreign subsidiary, resulting in significant tax savings from the foreign subsidiary's flow through losses.
PLRs 200637008/220649001: The IRS granted an extension of time to make a Code section 754 election, which resulted in significant tax savings to members of a family limited partnership.
PLR 201016010: The IRS granted an extension of time to make an S corporation election, which permitted the taxpayer to save significant income tax under Code section 118 on TIF proceeds.
PLR 201442066: The IRS approved a arrangement between a Code section 501(c)(3) charity and a private social club to preserve the club's historically significant facility.
Structured and implemented executive compensation arrangements to comply with complicated tax rules (e.g., Code sections 409A, 162(m) and 280G) while meeting clients' compensation goals. Examples include:
Phantom Stock, Stock Appreciation Rights and Restricted Stock Units
Incentive Stock Options and Employee Stock Purchase Plans
Nonqualified Stock Options and Restricted Stock
LLC Equity Incentive Plans and Profits Interests
Long-term Bonus Plans
Change of Control Agreements
SERPs and Elective Deferrals
Tax-Exempt Organization Plans (Code section 457(f) Plans)
Structured and formed several types of exempt entities and obtained IRS recognition of exempt status for both new and long-existing organizations. Unique examples include:
Obtained Code section 501(c)(3) status for a steam and chilled water facility that would serve several hospital systems.
Formed and obtained exemption for several "real estate" foundations that support public universities and allow for a more efficient process in developing university-centered real estate projects.
Converted a union training center to a Code section 501(c)(3) school, resulting in significant tax savings.
Obtained Code section 501(c)(3) status for a HMO that provides services only to Medicaid eligible populations.
Converted an online teaching platform company for public school children to a "supporting organization" to allow the organization to maintain public charity status.
Advised clients on the tax aspects of transferring real estate, including the following types of tax-free (Code section 1031) rollovers:
Forward exchanges using an intermediary
Reverse exchanges
Build to suit exchanges
"Drop and Swap" and "Swap and Drop" transactions involving partnerships
Assisted shareholders and LLC members in acquiring businesses, structuring ownership interests, planning for succession, restructuring and resolving disputes
Structured mergers and acquisitions to maximize after-tax proceeds to clients (when selling) or minimize tax costs after the transaction (when buying)
Structured and implement unique gifts to charity, including private company interests, real estate and conservation easements
Represented corporate, partnership and individual taxpayers before the IRS and various federal courts
Honors
Selected for inclusion in Best Lawyers in America - Tax Law; Business Organizations (including LLCs and Partnerships)
Selected for inclusion in Wisconsin Super Lawyers - Rising Star Edition (2007 to 2012)
Affiliations
Milwaukee Bar Association
State Bar of Wisconsin
Wisconsin Institute of Certified Public Accountants (Board of Directors and Federal Tax Committee)
News & Insights
COVID Relief Package – Key Tax Provisions for 2021
Alerts & Updates
93 Reinhart Attorneys Named 2020 Best Lawyers in America
Press Releases
97 Reinhart Attorneys Named 2019 Best Lawyers in America; 13 are “Lawyers of the Year”
In the News, Press Releases
The New Tax Law: Hot Issues You Should Know
Webinars & Presentations
Net Investment Income Tax Final Regulations Released
Alerts & Updates
LLCs and Partnerships:
Key Tax Provisions of Partnership and LLC Operating Agreements
Critical Partnership Tax Issues in Today's "Forced Allocation" World
Overview of Allocations and Tax Capital Accounts
Partnership Special Allocations and Guaranteed Payments
Advanced Capital Account Issues – "Book-ups" and Section 704(c)
Key Principles of Partnership Allocations: Substantial Economic Effect, 704(c) and Nonrecourse Deductions
Partnerships: Inside and Outside Basis
Partnership Basis – Debt Allocations
Partnership Basis – Death and Transfer: Code Sections 754 & 743(b)
Partnership Basis – Distributions and Allocating Basis Adjustments: Code Sections 754, 734(b) and 755
Partner W-2 Reporting and Self-Employment Tax Planning
Rul. 99-5 and 99-6 – Tax Traps, Opportunities and Open Issues
S Corporations:
S Corporations: Operations
S Corporations: Formation and Termination
Gifts of S Corp Stock to Charity
Executive Compensation:
Severance Arrangements – Key Tax Issues
Key Nonqualified Deferred Compensation Issues – Section 409A and Beyond
FICA and State Income Taxation of Nonqualified Deferred Compensation Plans
Equity-Based Compensation Alternatives
Other:
Employee/Independent Contractor Update
Checking-The-Box for Entity Classification on Form 8832
Legal Duties of Nonprofit Directors and Officers, Director Liability and Strategies to Protect Board Members
Key Issues in Purchase Price Allocations in M&A Transactions
LESSONS FROM THE TRENCHES: Key Issues and Strategies in Buying or Selling a Business
Creative Legal Structures for Historic Preservation Nonprofits
8% Net Investment Income Tax Final IRS Regs: Maximizing Planning Opportunities
New IRS Guidelines for Good Governance for 501(c)(3) Organizations and Corresponding Changes to IRS Form 990
Co-author, "Taming the Three-Headed Monster: FICA, SECA and NIIT Applied to Real Estate Activities," Bloomberg BNA Tax Management Real Estate Journal (April 2015)
Co-author, "3 Ways to Maximize Value in the Sale of Your Business," Milwaukee Business Journal's Business Law & Accounting Supplement (November 2014)
Co-author, "Tax-Exempt Organizations: Ensuring Governing Board Independence," Business Law & Governance (November 2010)
Co-author, "New Seventh Circuit Case Seems to Reject Adverse Tax Consequences of Reimbursement Agreements in Reasonable Compensation Cases," Taxes-The Tax Magazine (April 2010)