The Double Dip in Divorce: Business Value, Spousal Support, and the Overlap After Owen

Steven D. Wolfson
Steven D. Wolfson
Dickinson Wright

Steven Wolfson’s practice focuses on all areas of family law, including legal decision-making and parenting-time disputes, business valuations, spousal maintenance and high-income child support determinations and pre and post-nuptial agreements.

Thomas T. Field
Thomas T. Field
Beermann LLP

Thomas T. Field is an Equity Partner at Beermann LLP in Chicago, Illinois, where he heads the firm’s Family Law Practice Group. His practice covers matrimonial and family law, custody disputes, interstate and international relocation actions including Hague Convention matters, post-dissolution conflicts, and prenuptial and postnuptial agreements.

Live Video-Broadcast: October 27, 2026

2 hour CLE

Tuition: $195.00
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Program Summary

 

One Dollar of Business Income, Counted Twice in the Same Divorce

In December 2025 the Iowa Supreme Court decided In re Marriage of Owen and Brinker. Trial courts now have a new framework for the income-asset overlap. States remain split into three camps: some permit the overlap, some prohibit it categorically, and some apply a case-by-case equitable analysis. Where the case sits decides the argument counsel can make.

Capitalize normalized earnings and the income stream becomes property. Use that same stream for support and the payor pays twice. Set reasonable compensation too low and the valuation inflates. Set it too high and the support base swells. Misclassify goodwill and the double-dip argument never reaches the court.

Attendees walk out with the normalized-compensation framework, a three-column support-offset exhibit a court can follow, instructions a forensic expert can work from, and the jurisdictional map behind Grunfeld, Steneken, and the 2024–2025 Massachusetts and Connecticut decisions.

Key topics to be discussed:

  • The Owen Framework
    How Iowa’s December 2025 decision in In re Marriage of Owen and Brinker changes what a trial court must weigh.
  • Three-Camp Split
    Which states permit the overlap, which prohibit it categorically, and how to argue where no bright-line rule applies.
  • Valuation Method
    Why the income approach creates double-dip exposure the asset approach does not, and how goodwill classification gatekeeps the argument.
  • Normalized Compensation
    How the reasonable compensation adjustment sets the size of the overlap and moves value and support inversely.
  • Support-Offset Exhibit
    How to build the three-column exhibit and instruct a forensic expert so the valuation report supports it.
  • Case Law and Pitfalls
    What Grunfeld, Steneken, and the 2024–2025 Massachusetts and Connecticut decisions require, and which post-2019 tax traps amplify the error.

This course is co-sponsored with myLawCLE.

Date / Time: October 27, 2026

  • 2:30 pm – 4:40 pm Eastern
  • 1:30 pm – 3:40 pm Central
  • 12:30 pm – 2:40 pm Mountain
  • 11:30 am – 1:40 pm Pacific

Closed-captioning available

Speakers

Steven D. Wolfson, Member | Dickinson Wright

Steven Wolfson’s practice focuses on all areas of family law, including legal decision-making and parenting-time disputes, business valuations, spousal maintenance and high-income child support determinations and pre and post-nuptial agreements. Mr. Wolfson has been certified as a specialist in family law by the State Bar of Arizona Board of Legal Specialization since 2008.

  • Education & Credentials

Mr. Wolfson earned his Juris Doctor from the Sandra Day O’Connor College of Law at Arizona State University in 1991 and his Bachelor of Arts from Occidental College in 1985. He is admitted to practice in Arizona. He completed the Northwestern University School of Professional Studies Divorce Mediation Training, 40 hours, in October 2025, and Collaborative Law Training with ASU and the Collaborative Professionals of Phoenix in April 2026.

  • Recognition & Leadership

He is AV-rated as a preeminent attorney by Martindale-Hubbell. Mr. Wolfson was selected to be included in the Best Lawyers in America in the area of family law for 2010 through 2026. He has been selected for listing in Super Lawyers every year since 2007. Mr. Wolfson was also listed by Super Lawyers as a Top Attorney in Arizona for 2010 through 2025. He was also selected by Arizona State University, Sandra Day O’Connor College of Law to receive the Outstanding Alumnus Award, Class of 1991.

  • Professional Involvement

Mr. Wolfson serves as a Judge Pro Tem in the Maricopa County Superior Court for family law cases, a former representative of the State Bar Family Law Section to the Domestic Relations Committee (DRC) of the Arizona legislature, and is a member of the Maricopa County, State Bar of Arizona and American Bar Associations. He is a past chair of the State Bar of Arizona Family Law Section (2001-2002) and serves as the Legislative Liaison of the Family Law Section. He has been appointed to many committees of the Arizona Supreme Court. He is admitted to practice before the United States District Court for the District of Arizona and the United States Court of Appeals for the Ninth Circuit.

  • Experience

Mr. Wolfson obtained a $28 million judgment in a case that involved complex medical practice, commercial property, and equipment valuation issues, and a $24.5 million judgment in a case that involved valuation of a technology business. He is a frequent speaker on family law issues, with presentations including spousal maintenance calculations at the State Bar of Arizona Family Law Section annual meeting in June 2011 and family law legislation at the American Academy of Matrimonial Attorneys Arizona Family Law Institute in January 2014. He has presented “Legal Talk” for the AZ Court Help Program at the Coconino Law Library from 2023 to 2026, and he provides frequent television and radio commentary on family law issues.

 

Thomas T. Field, Equity Partner and Head of the Family Law Practice Group | Beermann LLP

Thomas T. Field is an Equity Partner at Beermann LLP in Chicago, Illinois, where he heads the firm’s Family Law Practice Group. His practice covers matrimonial and family law, custody disputes, interstate and international relocation actions including Hague Convention matters, post-dissolution conflicts, and prenuptial and postnuptial agreements. He is regularly engaged for matters requiring complex financial analysis of executive compensation, closely held businesses, and real estate.

  • Education & Credentials

Mr. Field earned his Master of Business Administration from the Stuart School of Business at the Illinois Institute of Technology in 2002 and his Juris Doctor from Chicago-Kent College of Law in 2001, following a Bachelor of Science, cum laude, from the University of Illinois at Urbana-Champaign in 1998. He was admitted to practice in Illinois and before the Northern District of Illinois in 2001. He was designated a Certified Financial Litigator by the American Academy for Certified Financial Litigators in 2020 and completed Mediation Skills Training at Northwestern University’s School of Professional Studies.

  • Recognition & Leadership

Mr. Field heads the Family Law Practice Group at Beermann LLP. He has been named to Best Lawyers in America from 2024 through 2027, to Lawdragon’s 500 Leading U.S. Family Lawyers in 2020, 2024, and 2025. Doyle’s Guide has listed him among the Preeminent Leading Family, Matrimonial and Divorce Lawyers and among Leading High Net Worth Family Lawyers. He has been selected to Super Lawyers and to the Leading Lawyers Network across most years since 2009, was named a Notable Gen X Leader in Law by Crain’s Chicago Business in 2022, and holds an AV Preeminent 5.0 Peer Review Rating from MartindaleHubbell.

  • Professional Involvement

Mr. Field is a member of the International Academy of Family Lawyers, the American Bar Association, the Illinois State Bar Association, the Chicago Bar Association, and the Lake County Bar Association, and he serves as a Board Member of Friends of the Israel Defense Force. He authored “Attorney Fees” for the LexisNexis Practice Guide for Illinois Family Law in 2015, updated in 2019. His presentations include “Executive Compensation: Innovative Images for Divorce” at the 2019 AACFL program and “Distressed Estates in Divorce.”

  • Experience

Mr. Field concentrates on matrimonial matters in which the marital estate turns on financial complexity: executive compensation packages, closely held business interests, and real estate holdings. He litigates custody and relocation actions across state and international lines, including Hague Convention proceedings. He represents C-suite executives of Fortune 500 companies and nationally recognized celebrities with an emphasis on discretion and on protecting a client’s public image.

Agenda

SESSION 1 – The Double-Dip Doctrine After Owen: How States Split on the Income-Asset Overlap | 2:30pm – 3:30pm

This session examines the double-dip doctrine in divorce—the problem that arises when the same business income stream is capitalized into a property valuation and then used again to calculate spousal support. Attorneys will analyze the Iowa Supreme Court’s December 2025 ruling in In re Marriage of Owen and Brinker alongside the national split among three distinct state-court camps: jurisdictions that permit the overlap, those that prohibit it categorically, and those applying a case-by-case equitable analysis. Attendees will leave able to identify the valuation method that triggers double-dip exposure, apply the normalized-compensation framework, and counsel clients on the doctrinal landscape across key jurisdictions.

BREAK | 3:30pm – 3:40pm

SESSION 2 – Quantifying the Double Dip: Normalized Earnings and the Support-Offset Exhibit | 3:40pm – 4:40pm

This session teaches attorneys how to identify, isolate, and quantify the income overlap between business valuation and spousal support in closely held business divorce cases. Attendees will learn how normalization adjustments create the mechanical double-dip, how to construct a support-offset exhibit that maps capitalized income against the support income base, and how recent decisions in Massachusetts, Connecticut, and New York define the operative legal standard. Attorneys will leave able to spot the overlap in a valuation report, instruct a forensic expert, and present the double-dip argument — or defend against it — with precision.

Credits

Alaska

Approved for CLE Credits
2 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Approved for CLE Credits
2 General

Arkansas

Approved for CLE Credits
2 General

Arizona

Approved for CLE Credits
2 General

California

Approved for CLE Credits
2 General

Colorado

Pending CLE Approval
2 General

Connecticut

Approved for CLE Credits
2 General

District of Columbia

No MCLE Required
2 CLE Hour(s)

Delaware

Pending CLE Approval
2 General

Florida

Approved via Attorney Submission
2 General Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Pending CLE Approval
2 General

Hawaii

Approved for CLE Credits
2 General

Iowa

Pending CLE Approval
2 General

Idaho

Pending CLE Approval
2 General

Illinois

Approved for CLE Credits
2 General

Indiana

Pending CLE Approval
2 General

Kansas

Pending CLE Approval
2 Substantive

Kentucky

Pending CLE Approval
2 General

Louisiana

Pending CLE Approval
2 General

Massachusetts

No MCLE Required
2 CLE Hour(s)

Maryland

No MCLE Required
2 CLE Hour(s)

Maine

Pending CLE Approval
2 General

Michigan

No MCLE Required
2 CLE Hour(s)

Minnesota

Pending CLE Approval
2 General

Missouri

Approved for CLE Credits
2.4 General

Mississippi

Pending CLE Approval
2 General

Montana

Pending CLE Approval
2 General

North Carolina

Pending CLE Approval
2 General

North Dakota

Approved for CLE Credits
2 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
2 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
120 General minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
2 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for CLE Credits
2 General

Nevada

Pending CLE Approval
2 General

New York

Approved for CLE Credits
2 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Pending CLE Approval
2 General

Oklahoma

Pending CLE Approval
2.5 General

Oregon

Pending CLE Approval
2 General

Pennsylvania

Approved for CLE Credits
2 General

Rhode Island

Pending CLE Approval
2.5 General

South Carolina

Pending CLE Approval
2 General

South Dakota

No MCLE Required
2 CLE Hour(s)

Tennessee

Approved for CLE Credits
2 General

Texas

Approved for CLE Credits
2 General

Utah

Pending CLE Approval
2 General

Virginia

Not Eligible
2 General Hours

Vermont

Approved for CLE Credits
2 General

Washington

Approved via Attorney Submission
2 Law & Legal Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Pending CLE Approval
2 General

West Virginia

Pending CLE Approval
2.4 General

Wyoming

Pending CLE Approval
2 General

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