Matters
- Represented real estate investment firm in connection with portfolio of real estate of over $700 million in connection with restructuring of business operations
- Assisting private equity sponsors and clients in establishing funds which have raised and deployed over $5 billion
- Assisting real estate sponsors and developers in establishing domestic and cross-border funds and joint ventures raising over $4 billion
- Represented private equity funds in acquisitions and sales of portfolio companies in transactions valued from $5 million to $2.5 billion
- Represented clients in establishing opportunity funds and over $1 billion of qualified investments
- Represented a public multinational in the U.S. Tax Court in connection with an IRS challenge to a cross-border “basis bump” acquisition, where the Tax Court ruled in favor of the taxpayer’s claim for stepped-up basis in assets despite finding strong tax motives for the transaction. Affirmed by the Court of Appeals for the Ninth Circuit
- Representing large public communications entity in Tax Court case involving corporate reorganization and issues of economic substance
- Represented large public transport company in case involving offshore insurance, where the Court of Appeals for the Eleventh Circuit ultimately issued a ruling in favor of the taxpayer, finding that coverage provided by an offshore insurer was true insurance for tax purposes and had true economic substance
- Represented large issuer of annuity contracts in IRS audit and Appeals in matter involving IRS adjustments of over $50 billion
