MichaelLobie

Michael has broad, but deep, tax law knowledge, and assists clients with tax planning, structuring, controversy, and litigation matters. He has extensive experience advising clients, including for-profit, nonprofit, and tax-exempt clients that range from Fortune 500 companies to universities, on the tax and corporate considerations that are relevant to entity choice, acquisitions, business combinations, dispositions, and operational issues. He also represents clients before the US Circuit Courts, the US Tax Court, various state tax courts, the Internal Revenue Service, and other state and local tax authorities on a variety of litigation and controversy matters.

Michael helps clients understand the tax implications of forming and operating as a pass-through entity (e.g., partnership, limited liability company, real estate investment trust, S corporation, Delaware statutory trust, etc.), as a nonprofit entity, and as a corporation. He partners with clients and colleagues to design, negotiate, and document corporate transactions, including cross-border and domestic mergers and acquisitions, as well as sales, joint ventures, and capital markets offerings, including private placement offerings. He advises nonprofit and tax-exempt clients on a wide variety of tax and other legal issues, including the unrelated business income tax, fractions rule compliance, and excess benefit transactions. He also works with clients to establish remote work arrangements that are compliant with tax and payroll laws. In the real estate industry, he regularly helps sponsor clients design, document, and launch Delaware statutory trust and qualified opportunity zone fund offerings; assists clients with planning, documenting, and executing tax-deferred, like-kind 1031 exchanges; and advises public and private real estate investment trusts on the unique tax rules that apply to them.