Fran Muracca's practice centers on advising leading middle market privately held business owners on a range of entity structure, transaction, tax, and disposition issues, including self-insured risk management through insurance captives. He advises on the form of business entity and structure of business acquisitions and dispositions to minimize federal income tax consequences. In addition, he counsels affluent families on wealth preservation and integrated succession planning and governance, including maximizing wealth through liquidity and diversification initiatives. He also advises the principal owners and chief executives of National Football League and National Hockey League franchises on ownership transition and succession.
In addition to his tax and business succession counseling, Fran represents clients in federal tax controversies at the administrative dispute resolution level before the IRS and in litigation before the U.S. Tax Court. He has successfully defended regional and national private business owners against challenges raised by the IRS involving unreasonable compensation, the valuation of non-marketable privately held business interests for wealth transfer tax purposes, constructive dividends, and tax-motivated transactions. He also has defended professional firms on challenges raised by the IRS involving "intermediary tax shelter" transactions.
Fran is a member of the Bloomberg BNA Tax Management Corporate Tax Advisory Board, the Board of Directors of The Pittsburgh Penguins Foundation, the Hockey Stocks Together Foundation, a Member organization of USA Hockey. He was a 2017 Jefferson Awards Foundation recipient. Fran is also recognized by Best Lawyers In America, Best Lawyers in American Lawyer of the Year 2013, Legal 500 and Pennsylvania Super Lawyers.
J.D., Duquesne University (1985)
B.A., University of Pittsburgh (1981) cum laude
Bloomberg Tax Management Portfolios
Boot Distributions and Assumption of Liabilities discusses the tax problems arising in connection with boot distributions by a corporation to shareholders and creditors.