Francis A.Muracca II (Fran)

Fran Muracca's practice centers on advising middle market privately held business owners and family offices on a range of entity structure, transaction, and U.S. tax issues, including captive insurance solutions, qualification and risk sharing, and distribution. He advises on the form of business entity and structure of business acquisitions and dispositions to minimize federal income tax consequences. In addition, Fran counsels affluent business owners on wealth preservation and on integrated succession and governance planning, including maximizing wealth through liquidity, diversification, and derivative initiatives.

Fran advises significant private entities and leading upper middle market companies. He also advises principal owners of professional sports teams on valuation, ownership rights, and structure. Fran sustained a multibillion valuation of an NFL team in an ownership dispute.

In addition to his holistic 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 United States Tax Court. He has successfully defended iconic sports brands and regional and national private business owners against challenges raised by the IRS involving the valuation of privately held business interests, unreasonable compensation, 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 national board of advisors for BNA Tax Management, a director of The Pittsburgh Penguins Foundation, and a member of the NHL HIFE (hockey is for everyone) diversity advisory committee. He is a 2017 Jefferson Awards Foundation recipient.