Chris Saddock Partner
Christopher D. Saddock practices business and individual tax planning for high-net-worth individuals and closely held corporations and partnerships. Chris has an extensive history serving private clients as a tax and business adviser by preparing and implementing complex business and holding structures, as well as maximizing tax efficiencies and ensuring compliance. His areas of specialty include: US passthrough entity planning, US trust and estate tax planning, mergers and acquisitions, fund formation, startups, cryptocurrency, and international income and estate tax planning.
- Corporate & Securities
- Georgetown University Law Center, Master of Laws, Taxation, 2013
- Southern Methodist University Dedman School of Law, J.D., 2012
- The University of Texas at Austin, 2003
- State Bar of Texas
- State Bar of New York
- US income tax planning: reorganization of holding structure for UK multinational company with US citizens, US redemption planning for large subchapter S Corporation, asset acquisitions ranging from $5 - $200 million, mergers of private entities with values up to $150 million, SAFE agreement and Convertible note planning, qualified opportunity zone fund formation, tax consequences of cryptocurrency transactions, US real estate tax planning
- US estate tax planning: formation of South Dakota directed trusts, Wyoming Private Trust Companies with underlying trust, US estate tax exclusion gift planning, SLAT planning, GRAT formation, and termination, loan planning
- US Charitable planning: Private Foundation, Public Charity, Donor Advised Fund formation, corporate blocker planning, charitable contribution planning including CLATS and CRUTS.
- Controversies: Estate tax audits for large estates, US immigration audit with up to $200 million amount in controversy, US Voluntary Disclosures for taxable amounts up to $50 million, closely held entity audits including S and C corporations, partnerships, LLCs treated as partnerships, and disregarded entities, non-US international voluntary disclosure experience.
Publications & Speeches
- “Converting a Grantor Trust to an ESBT” Pending publication March 2014, Probate and Property Journal
Amicus Brief, 5th Cir., US v. Macintyre
- Justice Advocate International Justice Mission, Dallas banquet planning committee
- Pro Bono Representation of Human Trafficking Victims in US tax controversies