Cliff Capdevielle focuses his practice on income and estate tax planning, tax controversies, and trust and estate matters. Cliff counsels high-net-worth US and international clients on a variety of tax and estate matters, individuals, families and businesses. His practice often requires him to advise clients on a variety of US-based and cross-border estate planning and wealth preservation matters with a focus on estate and gift tax minimization strategies, tax credits and incentives, and tax planning.

To maximize tax savings, Cliff uses sophisticated tax and estate planning techniques when drafting wills, trusts, prenuptial agreements, family limited partnerships, and LLCs. He also advises executors and trustees in the administration of complex estates and trusts, and he collaborates with business owners and investors to design estate plans, and transactional and organizational structures that minimize tax burdens.

For more than 25 years, Cliff has represented clients in significant tax disputes, negotiating favorable settlements with state and federal tax authorities on matters relating to the IRS andstate and local tax controversies. His experience also includes assisting international clients on creating tax efficient strategies for US-based investing, as well as other US income and transfer tax matters including trust and probate issues, matters relating to migration to and from the US, expatriation, residency tax matters, and asset protection planning.

Prior to joining MOBO, Cliff acted as managing attorney for a boutique San Francisco tax law firm, where he counseled clients on estate and income tax matters, tax credits and incentives, IRS, state and local tax controversies and related reporting obligations. Cliff began his tax career at Deloitte, where he focused on tax planning and tax compliance for high-net-worth US and international investors, and their closely held businesses.

Cliff is MOBO.

Areas of Practice

  • Tax Planning
  • Estate Planning
  • Probate & Trust Administration

Bar & Court Admissions

  • California
  • U.S. District Court Eastern District of California
  • U.S. District Court Northern District of California
  • U.S. District Court Central District of California

Education

  • University of San Diego
    • J.D. & LL.M. (Taxation)

  • University of California, Berkeley
    • B.A.

Speaking Engagements & Publications

  • Tax Treatment of Real Estate Dealers, Investors, and Professionals: Capital Gains vs. Ordinary Income Treatment, Opportunity Zones and 199A. This course covered the differences between real estate dealers, investors, and professionals, as well as the tax consequences of each classification.

  • Advanced Income and Estate Tax Planning Techniques for Owners of Closely Held Businesses. This CLE course provided trusts and estates attorneys with an in-depth analysis of advanced income and estate tax planning strategies for owners of closely held businesses under current tax law and in light of proposed tax law changes.

  • Vacation Homes: Tax Reporting, Rental vs. Personal Property, Maximizing Expenses. This course gave tax advisers a thorough look at the tax implications of buying and renting vacation properties, as well as an understanding of how to maximize deductions for vacation homes, selling strategies, and the impact of legislation on these properties to make them worthy investments.

  • Recent IRS Crackdown on Abusive Trust Arrangements: Taxation and Audit Triggers. This CLE/CPE webinar provided guidance to trusts and estates attorneys and tax professionals on recent IRS enforcement actions and examinations focused on abusive trust arrangements.

  • Advanced Gifting Strategies for Estate Planners: Balancing Income and Transfer Tax Benefits. This CLE webinar provided estate planners guidance on key gifting strategies for individuals and couples under current tax law and the impact of potential tax law changes.

  • Advanced Gifting Strategies for Estate Planners: Balancing Income and Transfer Tax Benefits. This CLE webinar provided estate planners guidance on key gifting strategies for individuals and couples under current tax law and the impact of potential tax law changes.

  • Estate Planning Nuances of Revocable Trusts After a Grantor's Death: Tax Rules and Reporting. This CLE course provided estate planning counsel with an advanced and practical guide to the tax rules, reporting challenges, and nuances of revocable trusts after a grantor's death.

  • Family Limited Partnerships in Estate Planning: Structuring and Income Tax Considerations This CLE course provided estate planners with a practical guide to utilizing family limited partnerships (FLPs) in estate planning under current tax law. The panel discussed the income tax and asset protection benefits of FLPs, and detailed how to withstand IRS scrutiny of transfers and operations.

  • Partnership Tax Issues in Estate Planning: Key Challenges and Guidance for Trusts and Estates. This CLE course provided trusts and estates counsel guidance for recognizing and overcoming critical tax issues of partnerships in estate planning. The panel discussed the fundamentals of partnership income tax rules for estate planners, maintaining capital accounts, and basis rules.

  • State Taxation of Cannabis: Interplay with Federal Taxation, Recent Cases and State Initiatives: Mitigating Sales, Growers, and Excise Taxes. This course addressed the state taxes imposed by states that have legalized/decriminalized cannabis and the interplay between federal and state tax treatment of businesses in the flourishing cannabis industry.