Jonathan SamelFor the past 30 years, Jonathan Samel has successfully combined his practical experience in business law, estates, real-estate law and financing matters with a detailed technical knowledge of tax law to assist clients around the Delaware Valley. His practice focuses on structuring and implementing business transactions and tax planning for closely held businesses and individuals. His work includes assisting clients with all legal and tax aspects of the formation and operation of various business entities, including proprietorships, partnerships, corporations, limited-liability companies and joint venture and he has substantial experience in negotiating and completing the purchase and sale of businesses, including asset purchases and sales, stock purchases and sales, corporate reorganizations, and other similar arrangements.
Jon has substantial experience in the area of estate and gift taxation and in drafting wills, trusts and other agreements which are designed to minimize taxes. He is also the chair of the Firm's Automobile Dealership Group which assists automobile dealers with the acquisition and sale of dealerships, franchise litigation, succession planning, tax and estate planning, real-estate law, environmental issues, employee relations and other regulatory issues affecting automobile dealers.
Jon is a member and past chairman of the Corporation, Banking and Business Law Committee of the Montgomery Bar Association. He is also a member of the Probate, Estates and Trusts Committee of the Pennsylvania Bar Association, and of the Montgomery County Estate Planning Council. He serves on the Advisory Board of the Delaware Valley Family Business Center. Jon received his undergraduate degree from the University of Rochester (B.A.1974), and his law and Master's degree in Tax Law from Temple University (J.D. 1978, LL.M. 1990).
Recent Representative Cases:
Business Law
* Represented a client through the sale of his family business. This multimillion dollar transaction involved a sale of business assets, a real-estate sale, seller financing, a consulting arrangement, non-competitive covenants, and the resolution of a number of significant financial, tax and environmental issues.
* Assisted a large real-estate developer with negotiating, structuring and then closing the buyout of his partner through the purchase of stock and partnership interests.
Family Business Planning
* Represented a couple who owned a large real-estate investment business and who decided to pass this business on to their two sons, who presently work with them. Jon devised and put in place an innovative plan which combined the use of family limited partnerships with trusts and wills. The plan has put the family in a position where it can save in excess of $3 million of taxes.
* Coordinated the transfer of a substantial family manufacturing business from three second-generation owners to six third-generation owners. This transfer involved a stock sale, two real-estate transfers, consulting agreements, financing arrangements, a new buy-sell agreement, life-insurance trusts and the updating of each owner's personal estate plan.
Estate Planning
* Represented an elderly widow who had recently developed health problems and who was worried that she would lose her home and her other property if she had to move to a long-term care facility. Jon assisted her and her children in putting a plan in place designed to preserve her assets and at the same time giving her assurance that she would continue to have full control of and access to the assets.
* Counseled a family that owns and operates automobile dealerships and a real-estate development business. Jon structured and implemented a plan whereby substantial ownership interests in real estate were transferred from the older generation to the younger generation on a tax-free basis, using a combination of gifts and sales to various trusts. The projected estate tax savings for the family exceeds $5 million.
Tax Planning
* Represented a family who, owning 100 acres of valuable farmland, decided to grant a conservation easement to the Commonwealth of Pennsylvania on most of the property. It was projected that the family would face almost $400,000 of capital-gain tax as a result of granting this easement. Jon was able to significantly reduce this tax by structuring the transaction so that the family members obtained significant charitable income-tax deductions and acquired two new properties through tax-deferred exchanges.
Speeches/Publications:
- Numerous articles for the Legal Intelligencer, which is the daily law journal for attorneys in Philadelphia and the surrounding counties, including to following articles:
- IRS Explains How an Innocent' Spouse Can Avoid Paying Back Taxes- February, 2002
- IRS Explains Adequate Disclosure' of Gifts- March, 2001
- Courts Continue to Disagree on Whether Clients Must Pay Taxes on Attorney Fees- September, 2001
- Trusts Are Important in Planning For Children With Special Needs- August, 2002
- Court Decision Attacks Off-Shore Asset Protection Trusts September 1999
- Non Citizen Spouses Are Subject To Special Estate And Gift Tax Rules October, 2001
- A Qualified Personal Residence Trust Can Reduce Your Taxable Estate- October, 2003
- Complex Tax Rules Affect Employee Stock Options- July, 2006
Professional and Civic Memberships:
- Pennsylvania Bar Association
- Member: Probate, Estates and Trusts Committee
- Montgomery Bar Association
- Member and past chairman, Corporation Banking and Business Law Committee
- Montgomery County Estate Planning Council
- Delaware Valley Family Business Center, Member of Advisory Board
Personal Interests:
Involved with Tiferet Bet Israel Synagogue in Blue Bell, Pa.- presently serving as Co-President
Works with son's not-for-profit corporation that educates people on fire prevention and emergency preparedness as they relate to the disabled community.
Enjoys reading about U. S. history, and is an avid baseball and football fan.
