• vcard
312.463.6244
  • Education
    • LL.M., Georgetown University Law Center
    • J.D., Loyola University Chicago School of Law
    • B.S., Saint Louis University

Edward J. Hannon concentrates his practice on providing advice and counsel to clients on the development of tax savings structures in real estate project, development joint ventures, investment in U.S. real estate by foreign investors and in mergers and acquisitions of private businesses.

Ed represents real estate owners and investors in the use of tax-oriented structures related to governance, entity formation and dissolution of issues. He frequently advises investors in opportunities to minimize U.S. tax costs related to real estate investments and transactions. He also has an in-depth understanding of regulations, including Section 1031 of the Internal Revenue Code and Delaware statutory trust and tenant common structure to facilitate the like kind exchange process.

Drawing from his years of experience, Ed drafts and negotiates tax provisions included in stock purchase agreements, merger agreements and tax sharing agreements for U.S. based businesses. He also specializes in working with strategic buyers and private equity firms and their in-house tax accountants in acquisitions and disposition ranging in value from $30 million to $500 million.

  • Representing a Chicago-based private equity firm in a transaction involving a roll-up of an automotive-based service sector. The transaction involved subsidiaries in the United States, Germany, and the United Kingdom.
  • Representing a strategic buyer in the acquisition of a competitor in the revenue cycle business.
  • Representing a foreign real estate company in the acquisition of a U.S. hotel property located in the U.S. Coordinated cross-border tax planning strategies with the client’s international accounting firm and developed strategies to minimize U.S. tax consequences of U.S. withholding tax and tax reporting requirements.
  • Representing real estate owners in like-kind exchange and the adoption of post-exchange refinancing structure. Directed issuance of tax opinion on the extraction of the refinancing proceeds in a tax free manner.
  • Representing a foreign real estate company in connection with the acquisition of a hotel property located in the U.S. This matter involved the coordination of various cross-border tax planning strategies with the client’s international accounting firm and the development of a strategy to minimize the U.S. tax consequences of U.S. withholding tax and tax reporting requirements.
  • Representing a Chicago-based developer in connection with a joint venture with the existing property owner to develop an industrial property.  This matter involved the negotiation of tax allocation provisions related to the contribution of the real estate and provisions to maximize application of Code Section 199A deductions,
  • Representing a Swedish-based technology company in the negotiation of various joint venture agreements in connection with the expansion of their business into the United States.
  • Representing the owners of a closely held corporation in the manufacturing industry in a stock sale to a U.S. buyer. This matter involved the development of a structure for the tax-free rollover of management-held shares, and the review of the tax consequences of the receipt of deferred purchase price in the form of stock of a thinly traded entity.
  • Representing a German-based company in connection with the sale of one of its U.S. subsidiaries to a strategic buyer and competitor. This transaction involved the negotiation of various tax sharing provisions and the adoption of a structure to minimize U.S. tax withholding costs on the distribution of the sale proceeds.
text icon Publications & Presentations
Foreign Investment in U.S. Real Estate: Impact of Tax Reform
Co-Presenter, Strafford Publications
May 2018
text icon Publications & Presentations
Tax Opportunities and Tax Traps for Real Estate Transactions
Co-author, Real Estate Finance Journal
February 2018
text icon Publications & Presentations
Using Delaware Statutory Trusts in Real Estate Investments
Co-Presenter, Strafford Publications
September 2017