MichaelLobie
Partner
Tax
mlobie@seyfarth.com
Michael partners with colleagues to help clients with the legal matters of designing and implementing a business structure and operational model that is tax-efficient, practical, and results-driven.
More About Michael
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.
Michael does a considerable amount of pro bono work. He often helps charitable organizations incorporate, set up internal policies and procedures, and apply for federal and state tax-exempt status.
Prior to joining the firm, Michael worked as an attorney for the US Department of Justice, Tax Division, and as a judicial clerk for a judge at the US Tax Court. As a result, Michael has an acute understanding of the aspects of a structure or transaction that may attract the attention of a government attorney.
Michael finds his work to be creative, meaningful, and rewarding. He enjoys working with colleagues in other disciplines and clients to help clients achieve their business and economic goals.
Michael does a considerable amount of pro bono work. He often helps charitable organizations incorporate, set up internal policies and procedures, and apply for federal and state tax-exempt status.
Prior to joining the firm, Michael worked as an attorney for the US Department of Justice, Tax Division, and as a judicial clerk for a judge at the US Tax Court. As a result, Michael has an acute understanding of the aspects of a structure or transaction that may attract the attention of a government attorney.
Michael finds his work to be creative, meaningful, and rewarding. He enjoys working with colleagues in other disciplines and clients to help clients achieve their business and economic goals.
- LLM, New York University School of Law
- JD, University of Connecticut School of Law
With honors
Certifications
- Certified Health Care Institute (HCI) professional, Seyfarth Shaw LLP (2022)
- Connecticut
- District of Columbia
- Massachusetts
- New York
- US Supreme Court
- US Court of Appeals, Eleventh Circuit
- US Tax Court
Related Services
Related Key Industries
Related News & Insights
-
Speaking Engagement
May 9, 2024
Cameron Weil, Michael Lobie, and Jiten Patel to Speak at ABA Annual RPTE National CLE Conference
-
Recognition
08/09/2023
Seyfarth's Cameron Weil, Jiten Patel, and Michael Lobie Chosen as Leaders of Respective ABA Committee Sections for 2023
-
Firm News
Dec 21, 2022
Seyfarth Names 22 New Partners
-
Speaking Engagement
Dec 14, 2022
John Napoli and Michael Lobie to Speak at Tax Executives Institute’s New York Annual Tax Symposium
- Recognized as a Recommended Attorney for Tax - US taxes - non-contentious, The Legal 500 (Legalese Ltd.) (2024)
- Selected for inclusion in New York Super Lawyers (Thomson Reuters) Rising Stars List (2020-2022, 2024)
- Federal Taxation of Real Estate - Chair, American Bar Association Section of Real Property, Trust and Estate Law
- Co-Author, "Relief at Last for Qualified Opportunity Zone Businesses with Pre-Pandemic Working Capital Safe Harbor Plans," Legal Update, Seyfarth Shaw LLP (April 15, 2021)
- Contributor, Doing Business 2022, World Bank Group (2021)
- Co-Author, "Certain Senior Living Facilities Can Elect Out of the Business Interest Limitation," ABA Real Property, Trust and Estate Law Section’s eReport (March 8, 2021)
- Co-Author, "Certain Senior Living Facilities Can Elect Out of the Business Interest Limitation," Legal Update, Seyfarth Shaw LLP (February 2, 2021)
- Co-Author, "IRS Extends Prior Relief to Opportunity Zone Investment Programs," Legal Update, Seyfarth Shaw LLP (January 25, 2021)
- Contributor, Doing Business 2021, World Bank Group (2020)
- Co-Author, "US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests," Legal Update, Seyfarth Shaw LLP (September 18, 2020)
- Co-Author, "President Trump Signs Four Executive Orders Providing or Extending Coronavirus Relief," Legal Update, Seyfarth Shaw LLP (August 10, 2020)
- Co-Author, "An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property Enacted by the CARES Act; Other Elections Relating to Business Interest Expense Limitation," Legal Update, Seyfarth Shaw LLP (April 14, 2020)
- Co-Author, "The IRS Extends Filing and Payment Obligations for Most Taxpayers and Performance of Certain Taxpayer Time-Sensitive Actions Until July 15, 2020, and Extends the Time for Performance of Certain Time-Sensitive IRS Actions by 30 Days," Legal Update, Seyfarth Shaw LLP (April 13, 2020)
- Co-Author, "The IRS Extends the 45-Day and 180-Day Deadlines for Section 1031 Exchanges Initiated Before March 13, 2020 and the Deadline to Reinvest Eligible Gains in a Qualified Opportunity Zone Fund Affected by COVID-19," Legal Update, Seyfarth Shaw LLP (April 10, 2020)
- Co-Author, "CARES Act Provides Tax Relief to Real Estate Businesses," Legal Update, Seyfarth Shaw LLP (March 31, 2020)
- Co-Author, "The IRS Announces a 'People First Initiative' That Will Temporarily Ease Taxpayer Payment Obligations and Postpone IRS Compliance Actions," Legal Update, Seyfarth Shaw LLP (March 30, 2020)
- Co-Author, "Final Regulations Clarify and Liberalize Many Rules Governing Qualified Opportunity Fund Formation and Operations," Legal Update, Seyfarth Shaw LLP (January 17, 2020)
- Contributor, Doing Business 2020, World Bank Group (2019)
- Co-Author, "USA," Global Legal Insights to: Corporate Tax 2018 (August 9, 2018)
- Contributor, Doing Business 2019, World Bank Group (2018)
- Co-Author, "Tax Reform Impact on Employers and Employees," Tax Reform Management Alert Series, Seyfarth Shaw LLP (December 21, 2017)
- Co-Author, "Tax Reform for REITs and Real Estate Businesses," Tax Reform Management Alert Series, Seyfarth Shaw LLP (December 19, 2017)
- Co-Speaker, "Current Trends for Special Investors and Investment Structures - REITs, DSTs, and Ozs," American Bar Association's 36th Annual Real Property, Trust, and Estate (RPTE) National CLE Conference, Washington, DC (May 10, 2024)
- Panelist, "Bring Out the Crystal Ball: the Legislative and Administrative Outlook Post Mid-Term Election," Tax Executive Institute (TEI) New York Chapter’s Fifty Ninth Annual Tax Symposium (December 14, 2022)
-
Co-Presenter, "HR Forum: Remote Workforce Issues to Consider," Webinar, Seyfarth Shaw LLP (April 7, 2021)
-
Co-Presenter, "New York Employment Law Update: A Look Back and A Look Ahead," Webinar, Seyfarth Shaw LLP (January 27, 2021)
- Co-Panelist, "The Complex World of Opportunity Zones: Meeting Reporting Requirements and Keeping Penalties at Bay," Knowledge Group Webinar (October 22, 2020)
- Panelist, “Tax Court Clerkships,” New York University School of Law, New York, NY (September 1, 2017)
- Annual Seyfarth Habitat for Humanity Day
Michael partners with colleagues to help clients with the legal matters of designing and implementing a business structure and operational model that is tax-efficient, practical, and results-driven.
More About Michael
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.
Michael does a considerable amount of pro bono work. He often helps charitable organizations incorporate, set up internal policies and procedures, and apply for federal and state tax-exempt status.
Prior to joining the firm, Michael worked as an attorney for the US Department of Justice, Tax Division, and as a judicial clerk for a judge at the US Tax Court. As a result, Michael has an acute understanding of the aspects of a structure or transaction that may attract the attention of a government attorney.
Michael finds his work to be creative, meaningful, and rewarding. He enjoys working with colleagues in other disciplines and clients to help clients achieve their business and economic goals.
Michael does a considerable amount of pro bono work. He often helps charitable organizations incorporate, set up internal policies and procedures, and apply for federal and state tax-exempt status.
Prior to joining the firm, Michael worked as an attorney for the US Department of Justice, Tax Division, and as a judicial clerk for a judge at the US Tax Court. As a result, Michael has an acute understanding of the aspects of a structure or transaction that may attract the attention of a government attorney.
Michael finds his work to be creative, meaningful, and rewarding. He enjoys working with colleagues in other disciplines and clients to help clients achieve their business and economic goals.
- LLM, New York University School of Law
- JD, University of Connecticut School of Law
With honors
Certifications
- Certified Health Care Institute (HCI) professional, Seyfarth Shaw LLP (2022)
- Connecticut
- District of Columbia
- Massachusetts
- New York
- US Supreme Court
- US Court of Appeals, Eleventh Circuit
- US Tax Court
Related Services
Related Key Industries
Related News & Insights
-
Speaking Engagement
May 9, 2024
Cameron Weil, Michael Lobie, and Jiten Patel to Speak at ABA Annual RPTE National CLE Conference
-
Recognition
08/09/2023
Seyfarth's Cameron Weil, Jiten Patel, and Michael Lobie Chosen as Leaders of Respective ABA Committee Sections for 2023
-
Firm News
Dec 21, 2022
Seyfarth Names 22 New Partners
-
Speaking Engagement
Dec 14, 2022
John Napoli and Michael Lobie to Speak at Tax Executives Institute’s New York Annual Tax Symposium
- Recognized as a Recommended Attorney for Tax - US taxes - non-contentious, The Legal 500 (Legalese Ltd.) (2024)
- Selected for inclusion in New York Super Lawyers (Thomson Reuters) Rising Stars List (2020-2022, 2024)
- Federal Taxation of Real Estate - Chair, American Bar Association Section of Real Property, Trust and Estate Law
- Co-Author, "Relief at Last for Qualified Opportunity Zone Businesses with Pre-Pandemic Working Capital Safe Harbor Plans," Legal Update, Seyfarth Shaw LLP (April 15, 2021)
- Contributor, Doing Business 2022, World Bank Group (2021)
- Co-Author, "Certain Senior Living Facilities Can Elect Out of the Business Interest Limitation," ABA Real Property, Trust and Estate Law Section’s eReport (March 8, 2021)
- Co-Author, "Certain Senior Living Facilities Can Elect Out of the Business Interest Limitation," Legal Update, Seyfarth Shaw LLP (February 2, 2021)
- Co-Author, "IRS Extends Prior Relief to Opportunity Zone Investment Programs," Legal Update, Seyfarth Shaw LLP (January 25, 2021)
- Contributor, Doing Business 2021, World Bank Group (2020)
- Co-Author, "US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests," Legal Update, Seyfarth Shaw LLP (September 18, 2020)
- Co-Author, "President Trump Signs Four Executive Orders Providing or Extending Coronavirus Relief," Legal Update, Seyfarth Shaw LLP (August 10, 2020)
- Co-Author, "An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property Enacted by the CARES Act; Other Elections Relating to Business Interest Expense Limitation," Legal Update, Seyfarth Shaw LLP (April 14, 2020)
- Co-Author, "The IRS Extends Filing and Payment Obligations for Most Taxpayers and Performance of Certain Taxpayer Time-Sensitive Actions Until July 15, 2020, and Extends the Time for Performance of Certain Time-Sensitive IRS Actions by 30 Days," Legal Update, Seyfarth Shaw LLP (April 13, 2020)
- Co-Author, "The IRS Extends the 45-Day and 180-Day Deadlines for Section 1031 Exchanges Initiated Before March 13, 2020 and the Deadline to Reinvest Eligible Gains in a Qualified Opportunity Zone Fund Affected by COVID-19," Legal Update, Seyfarth Shaw LLP (April 10, 2020)
- Co-Author, "CARES Act Provides Tax Relief to Real Estate Businesses," Legal Update, Seyfarth Shaw LLP (March 31, 2020)
- Co-Author, "The IRS Announces a 'People First Initiative' That Will Temporarily Ease Taxpayer Payment Obligations and Postpone IRS Compliance Actions," Legal Update, Seyfarth Shaw LLP (March 30, 2020)
- Co-Author, "Final Regulations Clarify and Liberalize Many Rules Governing Qualified Opportunity Fund Formation and Operations," Legal Update, Seyfarth Shaw LLP (January 17, 2020)
- Contributor, Doing Business 2020, World Bank Group (2019)
- Co-Author, "USA," Global Legal Insights to: Corporate Tax 2018 (August 9, 2018)
- Contributor, Doing Business 2019, World Bank Group (2018)
- Co-Author, "Tax Reform Impact on Employers and Employees," Tax Reform Management Alert Series, Seyfarth Shaw LLP (December 21, 2017)
- Co-Author, "Tax Reform for REITs and Real Estate Businesses," Tax Reform Management Alert Series, Seyfarth Shaw LLP (December 19, 2017)
- Co-Speaker, "Current Trends for Special Investors and Investment Structures - REITs, DSTs, and Ozs," American Bar Association's 36th Annual Real Property, Trust, and Estate (RPTE) National CLE Conference, Washington, DC (May 10, 2024)
- Panelist, "Bring Out the Crystal Ball: the Legislative and Administrative Outlook Post Mid-Term Election," Tax Executive Institute (TEI) New York Chapter’s Fifty Ninth Annual Tax Symposium (December 14, 2022)
-
Co-Presenter, "HR Forum: Remote Workforce Issues to Consider," Webinar, Seyfarth Shaw LLP (April 7, 2021)
-
Co-Presenter, "New York Employment Law Update: A Look Back and A Look Ahead," Webinar, Seyfarth Shaw LLP (January 27, 2021)
- Co-Panelist, "The Complex World of Opportunity Zones: Meeting Reporting Requirements and Keeping Penalties at Bay," Knowledge Group Webinar (October 22, 2020)
- Panelist, “Tax Court Clerkships,” New York University School of Law, New York, NY (September 1, 2017)
- Annual Seyfarth Habitat for Humanity Day