Whether you are going through a major transition such as a merger or acquisition, working on a high-stakes deal, or starting a new venture, complex tax issues often pervade the situation at hand. Nearly every business decision is likely to raise important tax considerations, which is further complicated by the fact that the tax rules are ever-changing. As trusted tax advisors to our clients, we help navigate the complex tax code to proactively manage your matter with experienced and sophisticated counsel.
HOW WE HELP
Our Tax attorneys are experienced advisors who enjoy partnering with clients to maximize business opportunities through structuring creative and tax-efficient solutions. We work to understand our clients' goals and react with sophisticated counsel to achieve their objectives. Our practice draws upon decades of experience in federal, state, and local tax laws.
Seyfarth’s Tax attorneys counsel on mergers and acquisitions and international taxation, as well as pass-through vehicles such as partnerships, joint ventures, and trusts. Our practice serves a wide range of domestic and international clients, from Fortune 500 corporations, banks, and real estate investors to private foundations, public charities, and universities.
In particular, companies have come to rely on our team’s deep experience with the tax implications of real estate transactions. Building on Seyfarth's strong real estate history, our attorneys offer big-picture advice on all types of real estate-related assets and interests, including shopping centers, REITs, REMICs, and real estate partnerships/LLCs. Our tax team provides skilled counsel on restructurings, consolidations, tax free like kind 1031 exchanges and frequently shapes tax-efficient real estate matters including the formation, operation and liquidation of REITS and UPREITS.
Recently, we have been closely monitoring and advising sponsors, investors, developers, and businesses dissect the details of sponsoring and investing in Qualified Opportunity Funds and how to take advantage of the unique tax benefits of the Qualified Opportunity Zone Program. We were among the first firms to help clients utilize this statute, including a project recently named the top Qualified Opportunity Fund in county for economic revitalization and social impact by GlobeSt.com and Real Estate Forum.
While understanding the need to avoid tax controversies, our lawyers stand ready to act when matters escalate. They fiercely advocate for clients in administrative hearings and litigation and successfully negotiate settlements that can eliminate or substantially reduce taxes and penalties.
Our specialized Tax-Exempt Organizations practice, which includes some of the country’s most preeminent attorneys, help clients navigate the unique tax, governance and business issues that govern such entities. Many of the country’s largest hospitals, health systems, universities, and other charitable organizations turn to us to serve as their outside legal counsel, managing tax and non-tax issues.
THE SEYFARTH EXPERIENCE
Seyfarth attorneys know that excellence in legal service delivery requires a team mindset. Our Tax team works seamlessly with clients, their employees and outside accountants, and colleagues across the firm to design and implement practical solutions. To deliver the best possible experience for clients, Seyfarth’s Tax attorneys often work alongside other practice groups in the areas of corporate law, mergers and acquisitions, real estate, labor and employment, employee benefits, executive compensation, and litigation.
Our capabilities are best showcased through real examples of our work. Examples of recent counseling and transactions include:
- Offered tax opinion and structuring counsel to the nation’s first syndicated Opportunity Zone Fund.
- Represented a public Japanese company on the tax-efficient structuring of its US presence through the acquisition of a $600 million business.
- Represented a REIT in a transaction to separate its office properties from its $1.2 billion portfolio of residential properties. The residential properties were contributed in a tax efficient manner to another trust. The reorganization was followed by a $300 million minority preferred equity investment by a private equity firm.
- Represent an equity REIT as special counsel to structure their real estate opportunity funds, provide opinions on REIT prohibited transaction matters, and structure tax-efficient investor strategies for foreign non-treaty investors in the opportunity fund.
- Represented a real estate company in its acquisition by a publicly traded REIT. In a highly complex transaction structured for tax-efficiency, the REIT and its operating partnership acquired our client and their affiliated entities in a combination tax-free contribution and tax-free merger.
- Represented a client on the structuring of a fund to enable foreign investors from non-treaty eligible jurisdictions to invest in US real estate in a tax-efficient manner. The fund was structured using corporate blockers to minimize US tax liability. Special attention and planning was required as a result of the revisions that were made to the Internal Revenue Code pursuant to the tax reform legislation passed at the end of 2017.
Related Trends
Related News & Insights
-
Media Mentions
11/06/2024
Steven Meier Discusses Potential Trump Administration Policy Changes on Taxes in Law360
-
Speaking Engagement
11/03/2024
Seyfarth to Sponsor and Ofer Lion, Douglas Mancino, and Steve Meier to Speak at 61st Annual Hawaii Tax Institute
-
Firm News
08/15/2024
220 Seyfarth Attorneys Chosen as Leaders in Their Fields by Best Lawyers in America 2025
-
Media Mentions
07/11/2024
Steven Richman Discusses Uses of Synthetic Distributions in the Private Equity Law Report
Recognition
-
Recognition
11/07/2024
Seyfarth Extends Rankings in ‘2025 Best Law Firms’ by Best Lawyers
-
Recognition
11/02/2023
Seyfarth Ranked One of ‘2024 Best Law Firms’ by Best Lawyers
-
Recognition
08/17/2023
210 Seyfarth Attorneys Chosen as Leaders in Their Fields by Best Lawyers in America 2024
-
Recognition
08/09/2023
Seyfarth's Cameron Weil, Jiten Patel, and Michael Lobie Chosen as Leaders of Respective ABA Committee Sections for 2023
Whether you are going through a major transition such as a merger or acquisition, working on a high-stakes deal, or starting a new venture, complex tax issues often pervade the situation at hand. Nearly every business decision is likely to raise important tax considerations, which is further complicated by the fact that the tax rules are ever-changing. As trusted tax advisors to our clients, we help navigate the complex tax code to proactively manage your matter with experienced and sophisticated counsel.
HOW WE HELP
Our Tax attorneys are experienced advisors who enjoy partnering with clients to maximize business opportunities through structuring creative and tax-efficient solutions. We work to understand our clients' goals and react with sophisticated counsel to achieve their objectives. Our practice draws upon decades of experience in federal, state, and local tax laws.
Seyfarth’s Tax attorneys counsel on mergers and acquisitions and international taxation, as well as pass-through vehicles such as partnerships, joint ventures, and trusts. Our practice serves a wide range of domestic and international clients, from Fortune 500 corporations, banks, and real estate investors to private foundations, public charities, and universities.
In particular, companies have come to rely on our team’s deep experience with the tax implications of real estate transactions. Building on Seyfarth's strong real estate history, our attorneys offer big-picture advice on all types of real estate-related assets and interests, including shopping centers, REITs, REMICs, and real estate partnerships/LLCs. Our tax team provides skilled counsel on restructurings, consolidations, tax free like kind 1031 exchanges and frequently shapes tax-efficient real estate matters including the formation, operation and liquidation of REITS and UPREITS.
Recently, we have been closely monitoring and advising sponsors, investors, developers, and businesses dissect the details of sponsoring and investing in Qualified Opportunity Funds and how to take advantage of the unique tax benefits of the Qualified Opportunity Zone Program. We were among the first firms to help clients utilize this statute, including a project recently named the top Qualified Opportunity Fund in county for economic revitalization and social impact by GlobeSt.com and Real Estate Forum.
While understanding the need to avoid tax controversies, our lawyers stand ready to act when matters escalate. They fiercely advocate for clients in administrative hearings and litigation and successfully negotiate settlements that can eliminate or substantially reduce taxes and penalties.
Our specialized Tax-Exempt Organizations practice, which includes some of the country’s most preeminent attorneys, help clients navigate the unique tax, governance and business issues that govern such entities. Many of the country’s largest hospitals, health systems, universities, and other charitable organizations turn to us to serve as their outside legal counsel, managing tax and non-tax issues.
THE SEYFARTH EXPERIENCE
Seyfarth attorneys know that excellence in legal service delivery requires a team mindset. Our Tax team works seamlessly with clients, their employees and outside accountants, and colleagues across the firm to design and implement practical solutions. To deliver the best possible experience for clients, Seyfarth’s Tax attorneys often work alongside other practice groups in the areas of corporate law, mergers and acquisitions, real estate, labor and employment, employee benefits, executive compensation, and litigation.
Related Practices
Our capabilities are best showcased through real examples of our work. Examples of recent counseling and transactions include:
- Offered tax opinion and structuring counsel to the nation’s first syndicated Opportunity Zone Fund.
- Represented a public Japanese company on the tax-efficient structuring of its US presence through the acquisition of a $600 million business.
- Represented a REIT in a transaction to separate its office properties from its $1.2 billion portfolio of residential properties. The residential properties were contributed in a tax efficient manner to another trust. The reorganization was followed by a $300 million minority preferred equity investment by a private equity firm.
- Represent an equity REIT as special counsel to structure their real estate opportunity funds, provide opinions on REIT prohibited transaction matters, and structure tax-efficient investor strategies for foreign non-treaty investors in the opportunity fund.
- Represented a real estate company in its acquisition by a publicly traded REIT. In a highly complex transaction structured for tax-efficiency, the REIT and its operating partnership acquired our client and their affiliated entities in a combination tax-free contribution and tax-free merger.
- Represented a client on the structuring of a fund to enable foreign investors from non-treaty eligible jurisdictions to invest in US real estate in a tax-efficient manner. The fund was structured using corporate blockers to minimize US tax liability. Special attention and planning was required as a result of the revisions that were made to the Internal Revenue Code pursuant to the tax reform legislation passed at the end of 2017.
Related Trends
Related News & Insights
-
Media Mentions
11/06/2024
Steven Meier Discusses Potential Trump Administration Policy Changes on Taxes in Law360
-
Speaking Engagement
11/03/2024
Seyfarth to Sponsor and Ofer Lion, Douglas Mancino, and Steve Meier to Speak at 61st Annual Hawaii Tax Institute
-
Firm News
08/15/2024
220 Seyfarth Attorneys Chosen as Leaders in Their Fields by Best Lawyers in America 2025
-
Media Mentions
07/11/2024
Steven Richman Discusses Uses of Synthetic Distributions in the Private Equity Law Report
Recognition
-
Recognition
11/07/2024
Seyfarth Extends Rankings in ‘2025 Best Law Firms’ by Best Lawyers
-
Recognition
11/02/2023
Seyfarth Ranked One of ‘2024 Best Law Firms’ by Best Lawyers
-
Recognition
08/17/2023
210 Seyfarth Attorneys Chosen as Leaders in Their Fields by Best Lawyers in America 2024
-
Recognition
08/09/2023
Seyfarth's Cameron Weil, Jiten Patel, and Michael Lobie Chosen as Leaders of Respective ABA Committee Sections for 2023