Silvio Reggiardo, III

Silvio Reggiardo, III


Silvio Reggiardo, III


Sil Reggiardo assists clients in structuring business transactions and wealth transfers.

Many of his projects are tax sensitive. His clients include closely-held businesses and individuals. Sil is an adept communicator and has a natural ability to connect with his clients.

Sil constantly strives to improve. Nearly thirty years after graduating from law school, he received a graduate tax law degree. Before joining Downey Brand in 1990, Sil worked with the international accounting firm of Ernst & Young in San Francisco. He is a California CPA (inactive).

Sil has been a Downey Brand Partner since 1999.


Estate Planning and Trust Administration

  • Advises clients in estate planning matters ranging from standard revocable trusts to complex estate freezes and multi-generational transfers. At the end of 2012, as we prepared to go over the fiscal cliff, structured wealth transfers designed to take advantage of both valuation discounts and transfer tax exemptions.
  • Helps clients administer estates and trusts. This can include preparing transfer documents and estate tax returns, making post-mortem asset allocations, and making tax elections. Recently assisted a client in deciding whether to opt out of the estate tax in lieu of certain basis adjustments, and then he prepared detailed tax forms with the related basis adjustment allocations.
  • Clients often need to put matters before a court, not just for probates but also for contested trust administrations or the amendment of irrevocable trusts. Guides clients through that process, which often requires court appearances. For example, recently represented a trustee of a 12-sibling trust.  We were able to work with a co-trustee and certain beneficiaries to avoid a significant dispute.
  • Advises clients in structuring transactions and settlements in a tax-efficient manner. For example, structured a settlement to produce a non-taxable basis recovery rather than a taxable gain, and structured a land improvement project to fit within certain tax-deferred like-kind exchange parking guidelines.

Tax Controversies

  • Recently settled a charitable gift tax dispute in U.S. Tax court for pennies on the dollar after finding technical flaws in the IRS’s argument. Pending matters involving sales tax on event tickets, sales tax on cement precast products, and income tax in a deferred like-kind exchange.
  • In many cases, clients need to know whether a proposed transaction will likely receive certain tax treatment if challenged. Recently advised one client regarding whether a subsidiary liquidation after a stock acquisition would be tax-free, and another client regarding whether a proposed corporate division would be tax free. Advises what changes should be made to a proposed transaction to produce a desired tax effect.
  • Large transactions often require tax opinions to satisfy lenders or other third parties who have a stake in the tax treatment of a transaction. Involved in rendering tax options in connection with a tax-free corporate acquisition.

Entity Formations

  • Clients often need advice regarding whether to form an entity for business operations and, if so, what type of entity to use (e.g., corporation, partnership or limited liability company). Advises clients regarding those decisions and, where applicable, regarding tax allocation provisions of joint venture agreements.

Outside General Counsel

  • Serves as outside general counsel for clients running closely-held businesses that need general business law advice, agreements, correspondence and other documentation.

Professional, Community And Pro Bono Involvement

  • Certified Public Account, California (inactive)
  • American College of Trust and Estate Counsel, Fellow (ACTEC)
  • California State Bar, Estate Planning, Trust and Probate Section, Former Executive Committee member, Chair of the Estate Planning and Legislation subcommittees
  • Sacramento County Bar Association, President, 2018 (former First Vice President, Second Vice President, Secretary-Treasurer, Pro Bono Committee Chair, Bylaws Committee Chair, and Tax Section Chair)
  • Sacramento Estate Planning Council, Former Board Member, Technical Forum Chair, and Technical Developments Committee Chair
  • Mercy Foundation, Planned Giving Committee, Former Board Member
  • El Dorado Community Foundation, Planned Giving Committee
  • Sacramento Diocese Catholic Foundation, Planned Giving Committee
  • Arthritis Foundation Northeastern California Chapter, Former Board Member
  • UC Davis School of Law, Visiting Lecturer at Estate Planning

Honors And Rankings

  • AV Preeminent® Rating by Martindale-Hubbell®
  • Best Lawyers in America©, Tax Law, 2018-2019
  • California State Bar Certified Specialist, Estate Planning, Trust & Probate Law
  • California State Bar Certified Specialist, Tax Law
  • Super Lawyers, Northern California Super Lawyers, Estate Planning & Probate, 2004, 2006-2018
  • Sacramento Magazine, Top Lawyer, Business/Corporate, Estate Planning & Probate, Tax Law, 2015-2018
  • Sacramento Business Journal, Best of the Bar, 2017-2018
  • American Jurisprudence Award
  • Intern for Justice John E. Benson, California 1st District Court of Appeal
  • Thurston Society

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