Micah W. BloomfieldPartner

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Offices


Services

Micah Bloomfield is a trusted advisor to insurance companies, funds, investment banks and creditor groups. His practice focuses on the taxation of financial products, including reinsurance transactions, derivatives, asset-backed securities, real estate investment trusts and structured notes.

He has extensive experience with cross-border tax treaties and the tax aspects of modified coinsurance, hedge funds, private equity funds and funds-withheld reinsurance transactions, including those based on regulation XXX, segregated accounts and bankruptcy reorganizations.

In addition, clients turn to Micah for advice on complicated financial laws and regulations at all levels. Representative matters range from assisting private equity funds in forming 953(d) insurance companies, to advising insurance companies and funds on FATCA compliance.

Micah is an active member of ISDA’s tax committee and frequently comments on proposed Treasury regulations. He has been recognized by Best Lawyers and Super Lawyers, and as one of The Legal 500’s Leading Lawyers.

Micah’s pro bono contributions include helping a synagogue navigate the complexities of applying for Homeland Security grants.


Representative Matters

  • Two private equity funds in forming 953(d) insurance companies in Bermuda
  • Tax work setting up real estate funds to invest in India
  • Insurance companies and funds on FATCA compliance
  • Clients in negotiating tax provisions in documentation for letters of credit, loans and derivatives
  • Funds regarding the use of favorable treaty provisions for investing in life settlements
  • Investor regarding tax exempt financing for a recycling project
  • Creditor groups in bankruptcy and out of court settlements

Honors & Awards

  • New York Super Lawyers
  • The Best Lawyers in America
  • The Legal 500 United States, Tax: Financial Product and Tax: US taxes: non-contentious

Memberships

  • Member, Financial Transactions Committee, American Bar Association (ABA)
  • Member, North America Tax Committee and Equity Swaps Working Group, International Swaps and Derivatives Association (ISDA)
  • Member, The New York Tax Study Group
  • Member, Wall Street Tax Association

Speeches & Events

Mr. Bloomfield frequently participates as a lecturer and panelist in many legal symposiums and seminars. Previous engagements include:
  • Panelist, “Tax-Related Tips for Real Estate LLC and LLP Agreements: Capital Commitments, Tax Allocations and Distributions, and More,” Strafford Publications CLE: Real Estate Joint Ventures, March 1, 2017
  • Speaker, REITs: Developments in REIT Conversions, FIRPTA and Other Changes in the Tax Extenders Bill, Strafford Publications Webinar, March 17, 2016
  • Speaker, REITs: Critical Tax Considerations, Clear Law Institute Webinar, July 14, 2015
  • Speaker, “871(m) – Overview and Current Regulations,” ISDA Symposium: Understanding Tax Related Provisions of the ISDA Master Agreement, March 13, 2015
  • Speaker, REITs for Real Estate and Tax Counsel, Strafford Live Webinar, November 6, 2014
  • Speaker, “New Financial Products Discussion: Dividend Equivalents; Bitcoin Notice,” Institute of International Bankers Annual Tax Seminar, June 17, 2014
  • Speaker, “Income Tax Aspects of Real Estate Transactions,” Real Estate Board of New York, June 11, 2014
  • Speaker, “The Application of Circular 230 to Financial Institutions,” ABA Tax Section Mid-Year Meeting, January 24–26, 2013
  • Speaker, Tax Issues For Real Estate Investment Trusts, Strafford Live Webinar, January 23, 2013
  • Speaker, “Section 871(m) Panel Discussion,” New York State Society of Certified Public Accountants, January 8, 2013
  • Speaker, “Income Tax Aspects of RE Transactions,” The Real Estate Board of New York, November 14, 2012
  • Panelist, “The Foreign Account Tax Compliance Act:  The Impact on Life Settlements,” DealFlow Media’s Life Settlements Conference, September 2012
  • Panelist, “What’s a Bank, as a Withholding Agent, To Do?  Section 871(m) and Withholding,” ABA Tax Section Annual Meeting, May 2012
  • Panelist, “Hot Topics in Taxation of Financial Products:  Cross-border Life Settlement Transactions – Tax Issues,” BNA/SFI Conference, December, 2011

Publications

Books
 
  • Authored Chapter of Reverse Mortgages and Linked Securities, John Wiley & Sons, 2011
  • Co-author, Real Estate Investment Trusts, Thomson Reuters/West, 2011 (updated 2016)
  • Authored Chapter of Life Markets, John Wiley & Sons, 2009
  • Authored Chapter of Business Workouts Manual, Second edition, Thomson Reuters/West, 2009
Other Publications
  • Co-author, “The Impact of the Tax Reform Act on the Insurance Industry,” AIRROC Matters, Spring 2018
  • Co-author, “New Rulings Present Opportunities, but Not Carte Blanche,” Columbia Journal of Tax Law’s Tax Matters, January 2013
  • Co-author, “IRS Proposes Regulations on Sovereign Investments,” BNA Daily Tax Report, November 29, 2011
  • Co-author, “The Truth of Sisyphus: An Overview of Corporate Income Tax Reform,” BNA Daily Tax Report, April 20, 2011
Online Publications
 
  • Co-author, “REIT Conversions,” PracticalLaw.com, October 2014
  • Co-author, “REITs: Common Pitfalls and Fixes Checklist,” Practical Law Company's Online REIT Primer, March 2011 (with updates)
Stroock Articles
 
  • Co-author, “Three Key Federal Income Tax Issues Raised by Cryptocurrencies," Stroock Special Bulletin, April 11, 2018
  • Co-author, “President Trump’s Tax Plan to be Revealed Soon – Where Do We Stand Today?” Stroock Special Bulletin, February 21, 2017
  • “Treasury Department Finalizes Definition of Real Property for Real Estate Investment Trusts (REITs),” Stroock Special Bulletin, August 31, 2016
  • Co-author, “When Is Your Tax Return a False Claim to the Government?” Stroock Special Bulletin, January 13, 2016
  • Co-author, “Bipartisan Budget Act Requires Partnerships to Share a Portion of the Audit Burden,” Stroock Special Bulletin, November 18, 2015
  • Co-author, “IRS Releases 871(m) Final Regulations – New Tests for Dividend Equivalents,” Stroock Special Bulletin, October 19, 2015
  • Co-author, “D.C. Circuit Court Rules Sec. 4371 Federal Excise Tax Does Not Apply to Foreign-to-Foreign Retrocessions,” Stroock Special Bulletin, July 28, 2015
  • Co-author, “IRS Issues Proposed Regulations on Insurance Companies That Will Be Treated as PFICs,” Stroock Special Bulletin, May 19, 2015
  • Co-author, “Good Things Come to Those Who Wait: The Section 336(e) Regulations Finally Finalized,” Stroock Special Bulletin, June 12, 2013
  • Co-author, “A Tale of Two PACEs: Commercial Success vs. Residential Repose,” Stroock Special Bulletin, March 15, 2013
  • Co-author, “Renewables Renewed,” Stroock Special Bulletin, February 14, 2013
  • Co-author, “The Final FATCA Regulations: A Crib Sheet,” Stroock Special Bulletin, February 1, 2013
  • Co-author, “Gunboat Diplomacy? Treasury Releases Model FATCA Intergovernmental Agreement,” Stroock Special Bulletin, August 6, 2012
  • Co-author, “Mortal or Venial? Section 871(m) and the Seven Deadly Sins of Equity Swaps,” Stroock Special Bulletin, February 3, 2012
  • Co-author, “IRS Proposes Regulations Addressing Notional Principal Contracts and Section 1256 Contracts,” Stroock Special Bulletin, September 16, 2011
  • Co-author, “New IRS Notice Relaxes FATCA Compliance Timeline in Response to Taxpayer Concerns,” Stroock Special Bulletin, July 26, 2011
  • Co-author, “Health Care System Overhaul: Tax Code Changes,” Stroock Special Bulletin, July 21, 2010
  • Co-author, “Congress Works to Close Carried Interest ‘Loophole,’” Stroock Special Bulletin, June 29, 2010
  • Co-author, “The Thirty Percent Solution? FATCA Provisions of the HIRE Act,” Stroock Special Bulletin, April 21, 2010
  • Contributor, “Health Care Reform: The Initial Impact,” Stroock Special Bulletin, March 26, 2010
  • Co-author, “IRS Grants Certain Taxpayers an FBAR Filing Deadline Extension to June 30, 2011,” Stroock Special Bulletin, March 1, 2010

Admitted To Practice

New York

U.S. Tax Court


Education

LL.M., New York University School of Law, 1985; Tax

J.D., cum laude, Harvard Law School, 1978

A.B., cum laude, Harvard University, 1975


 
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Publications