Senior Tax Counsel--Corporate Tax Research and Planning--Federal and SALT
• Provided advice regarding corporate and partnership tax planning issues, including evaluating domestic/international holding company structures, FTC and earnings repatriation planning, including withholding taxes, tax treaties, transfer pricing planning, documentation and implementation, qualified dividend planning, U.S. tax minimization, tax nexus, effectively connected income, financial products, FIRPTA, PFIC, CFC, PTP, TMP, tax shelter reporting and miscellaneous partnership and C corp tax issues and federal and state audit support and investor tax reporting questions.
• Advised on off-balance sheet structures across asset classes to maximize after-tax returns and improve Tier 1 capital and provided global tax advice in connection with diverse transactional and compliance issues for Firm proprietary balance sheet investments, as well as for strategic and minority fund investments such as DE Shaw, Och-Ziff and One William Street, and made recommendations with regard to U.S. and foreign issues associated with derivatives and other financing structures.
• Responsible for structuring and providing tax diligence regarding various REO structures, including RTC joint ventures and securitizations, bridge equity and various REIT structures, tiered joint venture and split ownership structures, equity leases, like kind exchanges, low income, and certified historic projects.
• Developed analyses for acquired businesses to optimize the SALT legal entity structure for the Firm, as well as assessed the federal, state and local impact of various sale/leaseback structures for the corporate headquarters facility in NYC, use of a stapled stock structure, explored investment capital and apportionment opportunities and UBT/OT planning and state and city audit support.