Lucas Love is a Partner in the firm’s Honolulu office and a member of its tax practice group. His practice includes tax planning for business transactions, international tax planning and compliance, tax controversy and audit defense, estate planning for large estates and small business owners, trust and estate administration, and non-profit organization formation and administration. Prior to joining Carlsmith, Lucas was an associate with Baker & McKenzie in Palo Alto, California, where he advised some of Silicon Valley’s largest companies on a variety of international tax planning and federal tax controversy matters. Prior to law school, Lucas was an accountant at Ernst & Young in Honolulu, Hawaii, where he audited the financial statements of some of Hawaii’s largest companies. In addition to his law degree, he has a master’s degree in accounting and is a Certified Public Accountant (not in public practice).
Tax Planning for Business Transactions
Lucas advises clients with the negotiation and documentation of the sale of businesses in various industries, including medicine, dentistry, construction, aviation, and real estate; choice of entity considerations following the passage of the 2017 Tax Act; all varieties of Section 1031 like-kind exchanges; the formation of corporate structures to utilize federal and State of Hawaii photovoltaic tax credits; the formation of tax-deferred Qualified Opportunity Zone Funds under IRC Section 1400Z-2; preparation of employment and deferred compensation agreements compliant with IRC Section 409A; and tax-free spin-off transactions under IRC Section 355.
International Tax Planning and Compliance
Lucas has structured tax-efficient inbound investments and exit strategies into and out of Hawaii by clients located in Japan, Korea, China, Taiwan, Singapore, Germany, and Canada. Lucas also advises local clients with their tax reporting obligations as to foreign assets and income, including those individuals seeking protection under the Offshore Voluntary Disclosure Program (OVDP) and Streamlined Procedures.
Tax Controversy & Audit Defense
Lucas advises individuals, businesses, trusts and estates in appealing IRS and State of Hawaii tax assessments and in seeking abatement of penalties and interest.
Estate Planning for Large Estates and Small Business Owners
Lucas prepares wills and trusts for estates large and small, including the creation of tax-planning trusts such as IDGT’s, CRAT’s, and QPRT’s. Lucas also structures succession plans for small businesses to transfer ownership to the next generation.
Trust and Estate Administration
Lucas advises trustees and executors regarding their duties in managing and winding down a trust or estate, including the preparation federal and State of Hawaii estate tax returns (Form 706 and Form M-6, respectively). Lucas has also represented trustees in litigation by beneficiaries; and represented beneficiaries in litigation against trustees.
Nonprofit Formation and Operation
Lucas assists individuals with the formation of tax-exempt nonprofit organizations, including the preparation of the necessary incorporation documents and the IRS application for tax-exempt status (Form 1023).
Distinctions
•Selected for the 2017 Emerging Young Business Leaders Program by the Honolulu Japanese Chamber of Commerce
•Judge Martin Pence Scholarship for Academic Achievement, University of California Berkeley, School of Law Deloitte Outstanding M.Acc. Student, University of Hawaii at Manoa
•Deloitte Outstanding M.Acc. Student, University of Hawaii at Manoa
•Beta Alpha Psi, Accounting Honor Society, University of Hawaii at Manoa
•Beta Gamma Sigma, University of Hawaii at Manoa
•Provosts’ Honors, University of California at Los Angeles
•Golden Key International Honor Society, University of California at Los Angeles
Publications
• The Tenth Circuit Invokes the Tax Injunction Act: No Decision on the Constitutionality of Colorado’s Reporting Requirements for Out-of-State Retailers, Baker & McKenzie: Tax News and Developments (October 2013)
• Malaysia Guidance on E-Commerce Combines Illuminating and No-So-Illuminating Aspects, Baker & McKenzie: Tax News and Developments (June 2013)
