FacultyFaculty/Author Profile
Richard M. Lipton

Richard M. Lipton

Baker & McKenzie LLP

Chicago, IL, USA


Richard Lipton is a partner in Baker McKenzie, Chicago. He advises on tax planning for corporations, partnerships and limited liability companies, and has handled numerous engagements in structuring partnership and real estate transactions.

Mr. Lipton served on the Internal Revenue Service Advisory Council, and is an adjunct professor at the University of Chicago Law School, where he teaches partnership taxation. Mr. Lipton is past Chair of the ABA Section of Taxation.

Practice focus

Mr. Lipton advises US and multinational clients on federal tax issues. He also has extensive experience in a number of other areas relating to tax law, including tax-exempt organizations and the rules involving unrelated business income tax, the tax consequences of bankruptcies and workouts, and various tax accounting issues. He also provides tax advice to several professional sports franchises.

Mr. Lipton has represented large corporations in complex partnership transactions, and has served as an expert witness on matters concerning partnerships and partnership taxation. He also has considerable experience in the areas of real estate investment trusts, real estate funds and investment in real estate by tax-exempt organizations and foreign investors.

Publications, presentations and articles

Mr. Lipton has authored a treatise and over 150 published articles on partnership and real estate tax matters, and has spoken at most major tax institutes in the country.

Professional affiliations

  • American Bar Association - Member, House of Delegates
  • American Bar Association, Tax Section - Member of Council
  • American College of Tax Counsel - Fellow; Former Chair
  • Chicago Bar Association - Former Chair, Federal Tax Committee

Admissions

  • U.S. Court of Federal Claims~United States (1980)
  • District of Columbia~United States (1978)
  • U.S. Tax Court~United States (1977)
  • Illinois~United States (1977)

Education

  • University of Chicago Law School (J.D.) (1977)
  • Amherst College (B.A.) (1974)
Richard M. Lipton is associated with the following items:
Treatise Chapters  Treatise Chapters Partner or Lender? Debt/Equity Issues Arise in Second Circuit’s Reversal of Castle Harbour - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Federal Circuit Upsets a LILO Deal, and Maybe the Law on Step Transactions and Substance Over Form - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Chemtech—The Fifth Circuit Reins in but Upholds the District Court - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Briarpark and the Unexpected Limits to Careful Tax Planning - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Reasonable Cause and Good Faith Reliance on an Advisor Help a Son-of-BOSS Taxpayer Avoid Penalties - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
SWF Real Estate: Tax Credits and Disguised Sales—Reasons for Concern - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
The Tax Court in Barnes Group Misapplies the Step Transaction Doctrine, Imposes Penalties - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Taxable Sale or Nontaxable Reorganization? Tax Court Draws a Distinction in Tribune Company - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
The STARS Are Not Aligned: Courts Split in Assessing an Alleged Tax Shelter Transaction - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
The ‘State of the Art’ in Like-Kind Exchanges—2015 - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Bad Facts Result in a Taxpayer Loss in the First SILO Case to Be Adjudicated - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
IRS Blunders in Treatment of NRCOs in CCA 201606027 - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
BNY and AIG—Using Economic Substance to Attack Transactions the Courts Do Not Like - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Who’s Afraid of Virginia Historic Tax Credit Fund? - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Notice 2015-54: IRS Attacks Transfers of Property to Partnership with Related Foreign Partners and Controlled Transactions Involving Partnerships - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Court of Federal Claims Rejects Taxpayer’s Claims of a Business Purpose in Heinz - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Bedrosian: The Tax Court Wades into a Procedural Morass Under TEFRA - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
The Tax Court Drains Canal Corporation - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
LILO Transaction Upset by District Court on Motion for Summary Judgment in BB&T - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
John Hancock—The Tax Court Applies Judicial Doctrines to SILOs and LILOs - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Eighth Circuit Sheds Light on Like-Kind Exchanges - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Tax Court Again Rejects Purchase from a Related Person of 1031 Replacement Property - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
In Klamath, the Fifth Circuit Clarifies Its Test for Economic Substance - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Proposed Regulations Address Debt Allocations for Partners and Related Parties - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
What Hath Congress Wrought: The Amendment to Section 6694 Will Cause Major Problems for Everyone - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
The STARS Continue to Revolve—The First Appellate Decision - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
‘Codification’ of the Economic Substance Doctrine—Much Ado About Nothing? - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Final Regulations for the Tax Shelter Disclosure Regime—Making the Rules More User Friendly - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
IRS Misses on the Boardwalk - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Son of BOSS Transactions: Taxpayers Win the First Round in Klamath - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
New Tax Shelter Cases and Notices Put Spotlight on the Economic Substance Doctrine - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Debt Workout Issues for REITs Are Complicated, Whether They Are Debtors or Creditors - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Legitimate and Illegitimate Tax Planning—Two Recent Cases Show the Way - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
‘Son of BOSS’ Update: Summary Judgment on the Tax Liability in Cemco but No Fraud in Sala - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
In Southgate, Economic Substance, Substance Over Form, and Penalties Are a Dangerous Mix - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
U.S. Taxation of Private Equity and Hedge Funds - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
IRS Provides Limited Relief for Section 1031 Exchanges That Fail Due to Default by a QI - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Castle Harbour III: A Taxpayer Victory as the District Court Refuses to Surrender - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
A Tale of Two Cases: G-I Holdings and Virginia Historic Tax Credit Fund—Can They Both Be Right? - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Proposed Regulations on Debt Allocations: Controversial, and Deservingly So - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Klamath Dispatches Another Tax Shelter, but Without Penalties - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
The "State of the Art" in Like-Kind Exchanges, 2009 - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
The World Changes: Broad Sweep of New Tax Shelter Rules in AJCA and Circular 230 Affect Everyone - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Will Black & Decker Turn Out to Be a Pyrrhic Victory for the IRS? - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
When Is a Partner Not a Partner? - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Hoosier Energy and the Limits of the Tax Law - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Second Circuit Sinks Castle Harbour (Again)—Did It Sink the FISC, Too? - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
CA-7 Sinks Penalties in One Son-of-BOSS Case, While Reg 1.752-6 Is Torpedoed Again in Another - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Passive Losses, LLCs and LLPs—Courts Reject IRS’ Attempt to Limit Losses - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Reliance on Tax Opinions: The World Changes Due to Long Term Capital Holdings and the American Jobs Creation Act - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
What Will Be the Long-Term Impact of the Sixth Circuit’s Divided Decision in Dow Chemical? - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
New Guidance Sheds Light on Economic Substance Doctrine and Related Penalties - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Final Corporate Tax Shelter Disclosure and List Maintenance Regulations Impose Burdens on Everyone - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Broad Scope of Section 470 Catches Many Non-Abusive Transactions - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
New Rehabilitation Credit Safe Harbor–Limiting Historic Boardwalk Hall - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Tax Shelters and the Decline of the Rule of Law - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
No ‘Bliss’ in New Phoenix Sunrise—Tax Court Rejects and Penalizes a Tax Shelter Transaction - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Taxation Meets Bizarro World: Passthroughs and Debt Workouts - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
What Will Be the Impact of the Government’s Victory in Coltec? - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Gateway Hotel Partners: Decision Illustrates the Disguised Sale Quandary - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Flextronics, Sundrup, and the Application of the Economic Substance Doctrine - The Partnership Tax Practice Series (2018 Edition), Tuesday, August 01, 2017
Wells Fargo Loses a SILO Case - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
‘Son of Boss' Update: Summary Judgment on the Tax Liability in Cemco but No Fraud in Sala - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
LILO Transaction Upset by District Court on Motion for Summary Judgment in BB&T - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Castle Harbour III: A Taxpayer Victory as the District Court Refuses to Surrender - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
BNY and AIG—Using Economic Substance to Attack Transactions the Courts Do Not Like - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
CNT Investors and the Judicial Doctrines - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Announcement 2010-9: Transparency or Overkill? - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
IRS Finalizes Revisions to Circular 230 - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
CA-7 Sinks Penalties in One Son-of-Boss Case, While Reg. 1.752-6 Is Torpedoed Again in Another - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Castle Harbour V—The Government Loses (Again) in the District Court - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
“Codification” of Economic Substance—Much Ado About Nothing? - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
New Guidance Sheds Light on Economic Substance Doctrine and Related Penalties - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Consolidated Edison—A LILO Transaction Succeeds on the Facts - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
The STARS Continue to Shine—Wells Fargo Prevails on Various Motions - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
No ‘Bliss’ in New Phoenix Sunrise—Tax Court Rejects and Penalizes a Tax Shelter Transaction - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Chemtech—The Fifth Circuit Reins in but Upholds the District Court - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Loving It: Appellate Court Confirms IRS Overstepped in Regulating Return Preparers - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
IRS Successfully Challenges a Midco Transaction in Enbridge - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
John Hancock—The Tax Court Applies Judicial Doctrines to SILOs and LILOs - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Court of Federal Claims Rejects Taxpayer’s Claims of Business Purpose in Heinz - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
The Final Section 6694 Regulations: New Rules for the Preparer Penalty - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Tax Shelters and the Decline of the Rule of Law - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
What Will Be the Impact of the Government’s Economic Substance Victory in Coltec? - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Federal Circuit Upsets a LILO Deal, and Maybe the Law on Step Transactions and Substance Over Form - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Countryside: The Tax Court Rejects the IRS Challenge to the Economic Substance of a ‘Real Deal’ - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Valero II: District Court Alters Its Views on “Tax Shelters” - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
The Tax Court in Barnes Group Misapplies the Step Transaction Doctrine, Imposes Penalties - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
New Ethical Guidance in Revisions to Circular 230 Will Affect All Tax Practitioners - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
The STARS Continue to Revolve—the First Appellate Decision - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Bad Facts Result in a Taxpayer Loss in First SILO Case - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Final Regulations for the Tax Shelter Disclosure Regime—Making the Rules More User Friendly - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Delaware Statutory Trusts and 1031: A Marriage Made in Heaven or Just a Pipe Dream? - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
The STARS Are Not Aligned: Courts Split in Assessing an Alleged Tax Shelter Transaction - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
‘Tough Loving’: District Court Invalidates IRS Regulation of Return Preparers - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
Preparer Penalties: The Service’s ‘Interim’ Response to the Section 6694 Amendments - The Corporate Tax Practice Series (2018 Edition), Thursday, February 15, 2018
CHB Chapters  CHB Chapters New Guidance Sheds Light on Economic Substance Doctrine and Related Penalties - Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018, Tuesday, May 01, 2018
U.S. Taxation of Private Equity and Hedge Funds - Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018, Tuesday, May 01, 2018
Live Seminar  Live Seminar Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2018, Wednesday, November 14, 2018, Chicago, IL
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