Representative Experience
- Represent Sealy Strategic Equity Partners, LP in connection with all federal income tax matters related to a $908 million sale of an industrial property portfolio to DRA Advisors
- Represent RW Holdings NNN REIT, Inc. in connection with all federal income tax matters related to the merger of the company with Rich Uncles Real Estate Investment Trust I, resulting in a $450 million self-managed REIT
- Represent Griffin Capital Essential Asset REIT II, Inc. in connection with all federal income tax matters related to the merger of the company with Griffin Capital Essential Asset REIT, resulting in a $4.7 billion self-managed REIT
- Represent Carter Validus Mission Critical REIT II, Inc. in connection with all federal income tax matters related to the merger of the company with Carter Validus Mission Critical REIT, Inc., resulting in a REIT with $3.2 billion of assets under management
- Represent fund in connection with all federal income tax matters related to the sale of stock in three private REITs for a sales price of more than $950 million
- Represent public non-listed REIT in connection with all federal income tax matters related to joint venture with private equity fund
- Prepare comprehensive tax opinions on various REIT-related tax matters, including application of preferential dividend rule to a multi-class stock structure
- Prepare and negotiate pre-filing agreement with IRS to claim a $2.5 billion bad debt deduction
- Represent creditors with respect to all federal income tax matters relating to bankruptcy of Washington Mutual, Inc., including negotiations over ownership of tax refunds and application of consolidated Section 382 rules
- Represent investors with respect to all federal income tax matters relating to $4 billion acquisition of a hotel REIT
- Prepare and negotiate private letter ruling requests on various tax matters, including application of REIT income and asset tests and S corporation qualification matters