Aaron Nocjar's practice focuses on US federal tax issues primarily in the ultra-high-net-worth space, with an emphasis on the taxation of pass-through entities and their investors. In that space, he advises multinational and family-run, closely-held businesses, high-net-worth individuals, and large pass-through entities. He advises clients in structuring transactions and planning for succession issues involving businesses and investments housed primarily in partnerships, limited liability companies, S corporations, and disregarded entities. He has practice experience in the energy (including alternative energy), private equity/venture capital/hedge fund, financial services, real estate, gemological, and consumer products sectors.
Aaron also assists these clients throughout the Internal Revenue Service administrative process, including navigating the old (TEFRA) and new (BBA) partnership controversy regimes.
He also helps clients address tax policy and implementation issues before Congress and the Treasury Department, including various issues related to pass-throughs and high net worth individuals arising from recent tax reform efforts.
Aaron regularly speaks on partnership and S corporation tax topics for the Tax Executives Institute, ALI-ABA, Practising Law Institute, Tax Management, Inc., Southern Federal Tax Institute, and other various bar and CPA groups.
- District of Columbia
- South Carolina
- Hon. Judge Irvin G. Condon, Charleston County Probate Court, South Carolina
- LL.M., Georgetown University Law Center, 2001, with distinction, Taxation
- J.D., Case Western Reserve University School of Law, 1998, magna cum laude, Order of the Coif, Executive Articles Editor, Case Western Reserve Journal of International Law
- B.B.A., University of Notre Dame, 1995, magna cum laude, Accountancy
Areas of Practice
- Assisting ultra-high-net-worth family with various business issues, with particular emphasis on joint venture exit issues, IRS and state examination issues, and ongoing business operational issues.
- Assisting large financial services partnership with several pass-through tax issues, including charitable contribution, passive activity loss, net investment income tax, self-employment tax, and partner compensation issues.
- Assisting various national associations with respect to pass-through and individual tax issues arising from tax reform efforts.
- Assisting ultra-high-net-worth individual in structuring and implementing a part-sale, part-rollover of an international family consumer products business.
- Handled due diligence review and resulting correction to prior individual and partnership tax returns for ultra-high-net-worth individual, leading to seven-figure reduction to taxable income.
- Assisting ultra-high-net-worth family in structuring family office investments and structuring to address family succession issues.
- Assisting one of largest closely-held businesses to address partnership tax issues arising from TEFRA examinations.
- Assisting ultra-high-net-worth family members regarding family succession issues.
- Assisting ultra-high-net-worth individual in exiting international joint investment venture, involving assets throughout the US, Europe, and Africa.
- Assisting ultra-high-net-worth family convert from S corporation holding structure to tax partnership structure.
- Assisting closely-held business restructure to attract private equity investments through UP-C structure and to plan for international expansion.
"The New Deduction for Qualified Business Income (Section 199A) - Nuts, Bolts, & Nuance," Tax Executive Institute Annual Conference, October 30, 2018
"Choice of Business Entity Issues Under the New Tax Act," State Bar of Arizona Convention 2018, Chandler, AZ, June 29, 2018
"The New Tax Law and Its Impact on Rates," Energy Bar Association Annual Meeting, May 7, 2018
"Section 385 Roundup: Nuances in Scope of Rules and Practical Insights into Compliance, State Tax Aspects, and Application to Passthroughs," Tax Executives Institute, March 21, 2017
"Using Partnerships in the Corporate Structure," Tax Executives Institute, April 27, 2016
"Consolidated Tax Return Regulations 2016," Practising Law Institute, February 22, 2016
"Consolidated Tax Return Regulations 2015," Practising Law Institute, February 23, 2015
News & Publications
August 13, 2018
November 6, 2017
February 22, 2017
October 13, 2016
May 4, 2016
April 14, 2016
May 7, 2019
Legal 500 US, Tax: US Taxes, Non-Contentious (2019)
Legal 500 US, Domestic Tax: East Coast (2013)
Thomas Bradbury Chetwood, S.J. Prize for attaining the highest academic average in his graduating class (LL.M. in Taxation) at Georgetown University Law Center
- Former Chair, Pass-Throughs and Real Estate Committee, Section of Taxation, DC Bar