Julia Caputo Stift handles federal, state, and local tax issues for foreign and domestic clients. She represents clients with respect to income, property, possessory interest, documentary transfer, and sales and use tax matters. Ms. Stift's practice emphasizes issues relating to tax-exempt entities, transactional, and tax planning matters.
Ms. Stift provides legal counsel regarding taxable and tax-free mergers, acquisitions and divisions, and the tax consequences of public and private offerings of equity and debt. Further, she provides choice of entity analysis, including formation and taxation of different business entities including, corporations, subchapter "S" corporations, partnerships, limited liability companies, and disregarded entities.
In representing tax-exempt organizations, Ms. Stift gives guidance on formation and operation, "unrelated business taxable income" issues, lobbying issues, joint ventures, affinity relationships, intermediate sanctions, self-dealing, and other issues unique to tax-exempt entities.
She also handles property tax assessment and protest matters, sales and use tax application analysis, and federal and state tax audits and protests.
Representative Work
Los Angeles Biomedical Research Institute at Harbor-UCLA Medical Center (formerly known as Harbor-UCLA Research and Education Institution). Counsels L.A. BioMed on a wide variety of tax matters. Tax issues recently handled for L.A. Biomed include establishment of procedures necessary to protect the organization's charitable, tax-exempt, 501(c)(3) status, unrelated business taxable income, private inurement and private benefit, donor advised giving, approval procedures for a variety of transactions pursuant to which parties with relationships with L.A. BioMed may receive an economic benefit, structuring of planned giving transactions, structuring of technology licensing and fee arrangements and charitable fundraising strategies.
Orange County Great Park Corporation (OCGPC). Counsels on a variety of tax matters for OCGPC, a charitable organization responsible for the re-development of the former El Toro Marine Base in Orange County, California. Tax advice has included assistance with compliance with federal income, state income, and state corporate restrictions and requirements, including the California Nonprofit Integrity Act of 2004 imposed on tax-exempt entities. Has also provided guidance on appropriate approvals processes for director and employee compensation, governance of charitable entities with interlocking directorates, private inurement and private benefit, conservancy of charitable assets, unrelated business taxable income, property tax application and exemption, sales and use tax, lobbying restrictions, and fundraising relationships and activities.
Sacramento County Employees Retirement System (SCERS). Advises SCERS, a nonprofit pension plan, on a wide variety of tax and other transactional and regulatory issues. Recently assisted SCERS and its family of organizations with a variety of unrelated business taxable income issues, issues associated with the use of single member limited liability companies as title-holding entities, and issues associated with the applicability of state taxes to government pension plans.
United Surgical Partner, Inc. (USPI). Counsels USPI regarding the formation of joint ventures to operating surgical centers. Provides guidance regarding tax allocations, tax disclosures, sales and use tax obligations and alternative minimum tax consequences of pass-through joint venture entities. Recently provided advice regarding the applicability of federal self-employment taxes to distributive shares of joint venturers.
Access to Loans for Learning Student Loan Corporation (ALL SLC). Advises ALL SLC, a charitable corporation that provides educational loans, on a wide variety of tax and other transactional and regulatory issues, including permissible programs and compensation arrangements. Recently assisted ALL SLC and its family of organizations in their expansion to new geographic areas and the secondary student loan market. Also advised ALL SLC on a wide variety of issues including unrelated business taxable income, affinity relationships, and joint ventures with for-profit and other charitable organizations.
Los Angeles City Employees Retirement System (LACERS). Advises LACERS, a nonprofit pension plan, on a wide variety of tax and other transactional and regulatory issues. Assisted LACERS and its family of organizations with a variety of unrelated business taxable income issues in connection with its acquisition of investment properties, property tax issues, and issues associated with the applicability of state taxes to government pension plans.
San Jose Police and Fire Department Retirement Plan (SJP&F). Advises SJP&F, a nonprofit pension plan, on a wide variety of tax and other transactional and regulatory issues. Recently assisted SJP&F with a variety of property tax issues, including possessory interest tax issues. Also advised SJP&F on a variety of unrelated business taxable income issues and issues associated with the applicability of state taxes to government pension plans.
Faculty Society, Harbor-UCLA Medical Center. Counsels on a wide variety of tax matters for the Faculty Society, a nonprofit mutual benefit corporation that was formed in 2005. Assisted the officers of the Faculty Society in establishing which form of organization best suited its goals and continues to provide ongoing advice regarding the proper tax and corporate characterization and treatment of this organization.