Mr. Libman received his J.D., magna cum laude, from Chapman University School of Law in 2001. In May 2008, Mr. Libman received his LL.M. in Business Law-Taxation from UCLA School of Law. Presently, Mr. Libman works at the taxation law firm of Wood & Porter in San Francisco, CA (www.woodporter.com). This discussion is not intended as legal advice and cannot be relied on for any purpose without the services of a qualified professional. The opinions in this article are solely those of the author and should not be attributed to Wood & Porter or anyone else other than David E. Libman. Mr. Libman wishes to thank his supervising professor, Andrew Katzenstein, Esq., for his gracious help and supervision in connection with the writing of this article. Mr. Libman also wishes to thank Rob Wood, Esq. for his advice, comments, and feedback regarding this article.