People: Ofer Lion, Partner

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Ofer Lion

Partner

Los Angeles - Downtown
Direct: (213) 270-9668
0

Ofer Lion is a tax partner in the Corporate department of Seyfarth Shaw LLP. He has represented nonprofits and tax-exempt organizations in a wide range of tax, transactional, corporate, governance and fiduciary matters, including formation, mergers and acquisitions, executive compensation, international activities and affiliations, unrelated business taxable income, joint ventures, program-related investments, political activities and lobbying, audits and tax controversies, tax return review, tax-exempt bonds and dissolutions.

He has extensively represented companies in all aspects of transactional tax matters, including mergers and acquisitions (domestic and cross-border taxable transactions, tax-free spin-offs, Section 351 transactions and corporate reorganizations), equity and debt securities finance, partnerships and private equity funds, real estate investment trusts (REITs), bankruptcy reorganizations, debt restructurings and state and local tax issues.

Mr. Lion has been quoted as a tax-exempt organizations authority in numerous news stories, including on NPR, by the Associated Press and in The New York Times, The Wall Street Journal, the Los Angeles Times, Tax Analysts, The Huffington Post, Forbes.com and Politico.com.

He has taught “Tax-Exempt Organizations: Law and Practice” as an adjunct professor at the UCLA School of Law.

Ofer Lion is a tax partner in the Corporate department of Seyfarth Shaw LLP. He has represented nonprofits and tax-exempt organizations in a wide range of tax, transactional, corporate, governance and fiduciary matters, including formation, mergers and acquisitions, executive compensation, international activities and affiliations, unrelated business taxable income, joint ventures, program-related investments, political activities and lobbying, audits and tax controversies, tax return review, tax-exempt bonds and dissolutions.

He has extensively represented companies in all aspects of transactional tax matters, including mergers and acquisitions (domestic and cross-border taxable transactions, tax-free spin-offs, Section 351 transactions and corporate reorganizations), equity and debt securities finance, partnerships and private equity funds, real estate investment trusts (REITs), bankruptcy reorganizations, debt restructurings and state and local tax issues.

Mr. Lion has been quoted as a tax-exempt organizations authority in numerous news stories, including on NPR, by the Associated Press and in The New York Times, The Wall Street Journal, the Los Angeles Times, Tax Analysts, The Huffington Post, Forbes.com and Politico.com.

He has taught “Tax-Exempt Organizations: Law and Practice” as an adjunct professor at the UCLA School of Law.

Education

  • J.D., University of California, Los Angeles, School of Law (2002)
  • B.A., Pennsylvania State University (1997)

Admissions

  • California

Affiliations

  • AHLA practice groups: Tax and Finance, Business Law and Governance
  • American Health Lawyers Association
  • Co-Chair, American Bar Association, Tax Section, Exempt Organizations Committee, Subcommittee on UBIT; Member, Exempt Organizations Committee, 2009–Present
  • California State Bar Association, Taxation Section, Tax-Exempt Organizations, 2006–Present
  • Chair, Exempt Organizations Practice Group, Los Angeles County Bar Association, 2008–2009; Member, 2003–Present

Presentations

  • Presenter, “Partnerships and Joint Ventures Involving Eos,” Representing and Managing Tax-Exempt Organizations, Georgetown Law CLE, Washington, D.C. (April 28, 2017)
  • Speaker, “A 20 Year Prospective - Exempt Organizations Through 2016,” Western Conference on Tax-Exempt Organizations, Los Angeles, CA (December 2, 2016)
  • Moderator, “Expecting the Unexpected in Property Tax Exemptions,” Western Conference on Tax-Exempt Organizations, Los Angeles, CA (December 1, 2016)
  • Speaker, “Funding Through Exploitation - Life Cycle of Nonprofit IP and Other Desirable Assets,” Western Conference on Tax-Exempt Organizations, Los Angeles, CA (December 1, 2016)
  • Speaker, “Nonprofits Governance and Fiduciary Duties - Recent Trends and the Essentials in Navigating Fiduciary Duties and Conflicts of Interest,” Hawaii Tax Institute, Honolulu, HI (November 7, 2016)
  • Speaker, “Governance Issues for Nonprofit Directors - Director Fees, etc.,” American Health Lawyers Association’s 2016 Conference on Tax Issues for Health Care Organizations, Arlington, VA (October 20 and 21, 2016)
  • Speaker, “Nonprofit Governance and Fiduciary Duties: Recent Trends in Navigating Fiduciary Duties and Conflicts of Interest,” LA-AiP Education Series, presented by The Los Angeles Chapter of Advisors in Philanthropy (October 11, 2016)
  • Speaker, “Impact of New Partnership Audit Rules on Tax-Exempt Organizations - The Bipartisan Budget Act of 2015,” ABA Section of Taxation, Boston, MA (September 30, 2016)
  • Speaker, UBIT Update, Subcommittee on UBIT, Exempt Organizations Practice Group Meeting, ABA Section of Taxation, Boston, MA (September 30, 2016)
  • Speaker, “Complex Gifts,” CalCPA Not-For-Profit Organizations Conference, Burbank, San Francisco, CA (May 24-25, 2016)
  • Speaker, “Non-profits in the Modern World - Hot Topics in Private Foundations, Charitable Giving and Impact Investing,” Glendale Estate Planning Council, Glendale, CA (March 15, 2016)
  • Speaker, UBIT update, Subcommittee on UBIT, Exempt Organizations Practice Group Meeting, ABA Section of Taxation, Los Angeles, CA (January 29, 2016)
  • Speaker, “Current Developments - Tax-Exempt Organizations,” Western Conference on Tax-Exempt Organizations, Los Angeles, CA (November 20, 2015)
  • Speaker, “Professional Opinions and Exempt Organizations,” Western Conference on Tax-Exempt Organizations, Los Angeles, CA (November 19, 2015)
  • Speaker, “Nonprofits in the Modern World: Hot Topics in Private Foundations, Charitable Giving and Impact Investing,” Hawaii Tax Institute, Honolulu, HI (November 2, 2015)
  • Speaker, “Monetizing the Intellectual Property of Health Care Organizations,” American Health Lawyers Association’s 2015 Conference on Tax Issues for Health Care Organizations (October 8, 2015)
  • Presenter, "Beyond Grantmaking: Program-Related Investments (PRIs) as Impact Capital," National Private Client Services team webinar, City National Bank (July 2015)
  • Speaker, “Beyond Grantmaking: Program-Related Investments (PRIs) as Impact Capital,” LA-AiP Education Seminar, Los Angeles, CA (May 12, 2015)
  • Speaker, UBIT update, Subcommittee on UBIT, Exempt Organizations Practice Group Meeting, ABA Section of Taxation, Washington, D.C. (May 8, 2015)
  • Moderator and panelist, “Tax-Exempt Organizations With Volunteers,” ABA Section of Taxation, Washington, D.C. (May 2015)
  • Faculty member, “Representing and Managing Tax-Exempt Organizations,” Georgetown University Law Center CLE, UBIT Primer, Washington, D.C. (April 24, 2015)
  • Presenter, "Nonprofits: Conducting Internal Investigations and Dealing with Embezzlement," Nonprofit Organizations Committee Meeting (March 12, 2015)
  • Speaker, “Program-Related Investments (PRIs): The New Venture Capital,” LA-AiP Education Seminar, Los Angeles, CA (June 12, 2014)
  • Speaker, CalCPA Education Foundation 2014 Not-for-Profit Organizations Conference, San Francisco, CA (May 21, 2014)
  • Speaker, “Tax Strategies for the High Income Individuals,” AICPA Conference, Las Vegas, NV (May 19-20, 2014)
  • Speaker, Roundtable Discussion: “Current Developments in Private Foundations, Unrelated Business Income, and International Philanthropy,” ABA Taxation Section 2014 Meeting, Washington, D.C. (May 9, 2014)
  • Moderator, Panel Discussion: “Hot Topics in UBIT,” ABA Taxation Section 2014 Meeting, Washington, D.C. (May 8, 2014)
  • Presenter, “Hot Topics for Nonprofits,” Meeting of the Nonprofit Organizations Committee, Business Law Section, California State Bar (February 18, 2014)
  • Presenter, Lunch and Learn program: “Private Foundations and Program-Related Investments: The New Venture Capital,” UCLA School of Law – Lowell Milken Institute for Business Law and Policy (February 5, 2014)
  • Moderator and Panelist, “Hot Topics in UBIT,” ABA Section of Taxation Exempt Organizations Committee Meeting (January 24, 2014)
  • Panelist, “Lessons on UBIT from the Final Report on Tax-Exempt Colleges and Universities Compliance Project (and a Few Other UBIT Updates),” Western Conference on Tax-Exempt Organizations (November 21, 2013)
  • Panelist, “Good to Great: Board Governance and Collective Decision Making,” The Nonprofit Breakfast Series (July 19, 2013)
  • Panelist, “Managing Liabilities: Optimizing leverage, credit available, and lower interest rates,” The Nonprofit Breakfast Series (June 27, 2013)
  • Speaker, “Program Related Investments: The New Venture Capital,” Nonprofit Organizations Committee – Business Law Section, California State Bar (December 11, 2012)
  • Speaker, “Investment Issues for Nonprofits,” Western Conference on Tax-Exempt Organizations (November 2012)
  • Speaker, “Current Developments Affecting Tax-Exempt Organizations,” The Community Foundation, Palm Springs, CA (October 10, 2012)
  • Speaker, “UBTI or Not UTBI — Tax-Exempt Investor Issues,” ABA Section of Taxation Real Estate Committee Meeting (September 14, 2012)
  • Speaker, Exempt Organizations Subcommittee on Unrelated Business Income, ABA Section of Taxation Exempt Organizations Committee Meeting (September 2012)
  • Speaker, Program-Related Investments (PRIs) and Private Foundations — What You Need to Know Now (September 12, 2012)
  • Speaker, “Legal Update for Not-for-Profit Organizations,” Grant Thornton LLP (June 6, 2012)
  • Speaker, Exempt Organizations Subcommittee on Unrelated Business Income, ABA Section of Taxation Exempt Organizations Committee Meeting (May 11, 2012)
  • Speaker, “Family Foundations: Practical Problems and Practical Solutions,” ABA Section of Taxation Exempt Organizations, American Bar Association (May 2012)
  • Speaker, Western Conference on Tax-Exempt Organizations, Lobbying and Political Activities (November 2011)
  • Speaker, Green Hasson Janks Nonprofit Workshop: Volunteer Engagement (November 2011)
  • Speaker, “Focus on Revenues: Cancellation of Debt, Pledges, Sponsorships and Special Events,” California Society of CPAs, Nonprofit Discussion Group (January 2011)
  • Speaker, 6th Annual Healthcare Law Compliance Symposium (October 2009)
  • Co-organizer and Moderator, “Corporate Issues in Board Governance and Nonprofit Finances in Today’s Economy, 2nd Annual Tax-Exempt Organizations General Counsel’s Forum (May 2009); conceived and coordinated the initial forum (May 2008)
  • Presented revised Form 990 issues to the California Society of Association Executives (November 2008)

Publications

Accolades

  • “Southern California Rising Stars,”Super Lawyers magazine (2011-2015)
  • Selected for inclusion in The Best Lawyers in America©, Non-Profit/Charities Law (2013-2017) and Corporate Law (2017)

Media Mentions

  • Quoted, “New International Tax Reporting May Snag Big U.S. Nonprofits,” Bloomberg BNA (November 7, 2016)
  • Quoted, “DNC Host Committee Adviser Says Exemption Doesn't Matter,” Tax Notes Today (July 19, 2016)
  • Quoted, “Hatch Asks IRS About Private Museums' Exploitation of Tax Code,” Tax Notes Today (June 3, 2016)
  • Quoted, "Foundations Revealed in Panama Papers Unlikely to Be U.S. EOs," Tax Notes Today (May 6, 2016)
  • Quoted, “Court Wrangling Persists Over California Donor Disclosure Rule,” Tax Notes Today (December 3, 2015)
  • Quoted, "Revoking Exemption of Group Tied to Church Shooter Is Not Simple," Tax Notes Today (July 1, 2015)
  • Quoted, "Charities Not Feeling Any Love For Donor Disclosure Ruling in California," Bloomberg BNA Daily Tax Report (June 1, 2015)
  • Quoted, "Briggs-associated nonprofits flout state, federal laws," inewsource (May 28, 2015)
  • Quoted, "NFL May Have to Flout Exemption Rules to Drop Status," Tax Notes Today (May 1, 2015)
  • Quoted, "Reliance Standard for Form 1023-EZ Clarification Aimed at Insiders, Attorney Says," Bloomberg BNA (March 26, 2015)
  • Quoted, "Bill Expanding Gift Tax Exemption Heads to Ways and Means Markup," Bloomberg BNA (March 24, 2015)
  • Quoted, "Reliance Standard for Form 1023-EZ Clarification Aimed at Insiders, Attorney Says," Bloomberg BNA Daily Tax Report (March 20, 2015)
  • Quoted, "As Super Bowl Approaches, Exemption Debate Persists," Tax Analysts (January 30, 2015)
  • Quoted, "Lawyer Seeks Guidance on Grants to 1023-EZ Orgs," CharitablePlanning.com (November 5, 2014)
  • Quoted, “Pace of Exempt Applications Picks Up At IRS, but Some See It Coming at a Price,” Bloomberg BNA Daily Tax Report (October 31, 2014)
  • Form 1023-EZ Turnaround Said to Be Two to Three Weeks for 501(c)(3) Exempts, BNA Daily Tax Report (July 24, 2014)
  • Quoted, IRS Groups Should Provide Specific Numbers When It Revises 501(c)(4) Rules, Groups Say, Bloomberg BNA Daily Tax Report (June 19, 2014)
  • Ofer Lion Voices Concern Over Ways and Means Committee’s Confidential Tax Information Disclosure, Tax Analysts (May 5, 2014)
  • Quoted, Most Exempt Applications Moving To Cincinnati as Unit Reorganizes, Bloomberg BNA Daily Tax Report (April 14, 2014)
  • The New York Times Quotes Ofer Lion on Friends of Abe Tax-exempt Status (March 16, 2014)
  • Debate Continues Over College Athletics Being Subjected to Unrelated Business Income Tax (February 18, 2014)
  • Quoted, NFL's Tax Exemption Faces Scrutiny, Tax Analysts (November 25, 2013)
  • Ofer Lion Speaks with Tax Notes About NFL Tax-Exempt Status (November 25, 2013)
  • Quoted, Practitioners Fear EO Controversy Is Causing IRS to Neglect 501(c)(3) Applications, Tax Analysts  (September 11, 2013)
  • Quoted, Don't Rush to Judgment on IRS-FEC E-Mails, Practitioners Say, Tax Analysts (August 7, 2013)
  • Quoted, IRS Gift Rule Turned on Politics as Crisis Prompts Reform, Bloomberg (June 3, 2013)
  • Quoted, Observers Expect More Self-Declaration in Wake of Scandal, Tax Notes Today (May 20, 2013)
  • Quoted, Watchdog slams U.S. IRS over targeting conservative groups, The Chicago Tribune (May 14, 2013)
  • Quoted, IRS Tea Party Targeting Came After Court Rulings Upended Agency Role,Huffington Post (May 14, 2013)
  • Quoted, Senators Seek IRS and FEC Cooperation on Campaign Finance Enforcement, Tax Notes Today (April 25, 2014)

Courts

  • California Supreme Court
  • U.S. District Court for the Central District of California
  • U.S. District Court for the Southern District of California
  • U.S. Court of Appeals for the Ninth Circuit