Michelle M. Jewett

Michelle Jewett focuses on all areas of federal income taxation, offering deep experience in corporate, mergers and acquisitions, partnership, financial instruments, private fund structures, insurance and reinsurance transactions, intellectual property and real estate investment trusts, both domestically and internationally.

Michelle has advised on structuring cross-border taxable and tax-free mergers, acquisitions and dispositions, domestic and foreign private equity investments, real estate investments by taxable and tax-exempt entities, mortgage-backed securities and other securitization transactions, leveraged leases, various international investments and transactions, bankruptcy and debt workouts, renewable energy investments and corporate transactions in the insurance industry.

She has structured numerous cross-border arrangements, including U.S. and foreign private equity funds, real estate funds, timber funds, energy and infrastructure funds, credit funds, and hedge funds. In addition, Michelle regularly advises clients regarding the tax issues associated with infrastructure, real estate and renewable energy investments.

Michelle contributes pro bono service forming and advising 501(c)(3) organizations, and represents low-income taxpayers in making offers in compromise with the IRS, resolving tax disputes, and dealing with employee classification.

Michelle has been named a Rising Star by Law360 and IFLR1000, recommended as a leading lawyer by The Legal 500 and included in Euromoney Legal Media Group Americas Women in Business Law Awards Shortlist for Best in Tax.

• Commodities / Derivatives / Energy
• Corporate
• Family Office
• Mergers, Acquisitions and Joint Ventures
• Private Equity / Venture Capital
• Qualified Opportunity Zones
• REITs
• Real Estate
• Tax

• IFLR1000, Deal of the Year: Banking and Finance 
• IFLR1000, Rising Star and Top Attorneys Under 40
• Law360, Rising Star
• The Legal 500 United States, Tax: Financial Product and Tax: US taxes: non-contentious in 2018 and 2019
• Euromoney Legal Media Group Americas Women in Business Law Awards Shortlist for Best in Tax

• Board Member, Emma's Torch
• Member, National Association of Real Estate Investment Trusts

• Panelist, "Qualified Opportunity Funds, Opportunity Zones and ESG Investing Conference," NYSSCPA, September 17, 2020
• Speaker, “COVID-19 Related Tax Considerations for the Real Estate Industry,” Harvard Law School Association of New York City Webinar, April 24, 2020
• Speaker, “Pandemic Not Panic: What Fund Managers Should Do Post-CARES Act,” Stroock Webinar, April 9, 2020
• Speaker, “Tax Issues Affecting Family Offices,” Stroock’s Second Annual Family Office Symposium, November 13, 2019
• Speaker, “The Challenges for Debt Investing,” 2019 AFIRE Tax & Regulatory Summit, November 7, 2019
• Speaker, “DWNA: Stroock debt finance and tax experts unravel Final Regulations to IRC Section 956,” Debtwire Radio, September 24, 2019
• Speaker, “The Ultimate Roundtable: A Deep Dive into the Critical Tax Issues Affecting QOZ Fund Formation and Administration,” NYSSCPA’s 1st Annual Qualified Opportunity Funds and Opportunity Zones Symposium, June 19, 2019
• Speaker, “Structuring Redemptions of Partnership and LLC Interests: Issues Unique to Liquidating Distributions,” Strafford Webinar, February 13, 2019
• Speaker, “Tax Reform – Significant Changes for the Energy Industry,” Practising Law Institute Webcast, September 26, 2018
• Speaker, “IRC Section 734 Adjustments: Applying the 754 Election to Distributions of Partnership Property,” Strafford’s Partnership Tax: Planning, Accounting, Reporting and Tax Reform Seminar, May 9, 2018
• Panelist, “Securing Foreign Capital 2018: An Interactive Roundtable Discussion,” The 15th Annual Winter Forum on Real Estate Opportunity & Private Fund Investing, January 17–19, 2018
• Speaker, Structuring Redemptions of Partnership and LLC Interests: Navigating Issues Unique to Liquidating Distributions, Strafford Webinar, June 14, 2017
• Panelist, “Fund Exits 2017: What is the Best Exit Strategy in Today’s Market?” The 14th Annual Winter Forum on Real Estate Opportunity & Private Fund Investing, January 18–20, 2017
• Panelist, “Advanced Compensation Part 2: Much Ado about Management Fee Waivers,” 7th Annual Private Investment Funds Tax Master Class, May 25–26, 2016
• Speaker, PATH Act: Major Changes to the REIT and FIRPTA Rules, Teleconference, March 8, 2016
• Panelist, “Fund Exit Strategies: Go Public, Liquidate Assets or Go the M&A Route?” The Winter Forum on Real Estate Opportunity & Private Fund Investing, January 20–22, 2016
• Panelist, IMN’s 11th Annual Non-Traded REIT Industry Symposium, June 26–27, 2014
• Panelist, “Understanding and Complying with Regulatory Updates and Developments,” IMN’s Real Estate CFO Forum, May 5–6, 2014
• Speaker, SEIA Webinar: The Fundamentals of Solar Financing, Webinar, March 21, 2014
• Panelist, “The Good, the Bad and the Ugly of Exit Strategies – What Non-Traded REIT Sponsors Need to Know, Do & Avoid,” IMN’s Annual New York Non-Traded REIT Industry Symposium, June 20–21, 2013
• Speaker, IQPC 11th Timberland Investment World Summit, January 29–30, 2013
• Speaker, “Infrastructure Investment: The Next Big Opportunity for Non-Traded REITs?” 8th Annual NY Non-Traded REIT Industry Symposium, June 23, 2011
• Panelist, SARTA – CleanTech Showcase, October 26, 2010

• Co-author, "IRS Extends COVID Relief for Qualified Opportunity Zone Funds and Investors," Stroock Client Alert, January 26, 2021
• Co-author, “Business-Related Tax and Employee Benefits Provisions in the Consolidated Appropriations Act,” Stroock Client Alert, December 31, 2020
• Co-author, “Renewable Energy Under a Biden Administration,” Stroock Client Alert, December 22, 2020
• Co-author, “IRS Issues Relief for Qualified Opportunity Zone Investors,” Stroock Special Bulletin, June 8, 2020
• Co-author, “Renewable Energy Projects May Benefit From the IRS Notice Expanding Safe Harbors,” Stroock Special Bulletin, June 1, 2020
• Co-author, “The April IRS Guidance on CARES Act and Other Relief,” Stroock Special Bulletin, April 28, 2020
• Co-author, “IRS Issues Corrective Amendments to QOZ Regulations and Additional Time for Taxpayer Reinvestment Into QOFs ,” Stroock Special Bulletin, April 17, 2020
• Co-author, “Navigating Coronavirus: Updates for REIT General Counsel,” Stroock Special Bulletin, April 9, 2020
• Co-author, “The CARES Act – Implications for Fund Managers,” Stroock Special Bulletin, April 6, 2020
• Co-author, “The CARES Act’s Tax Provisions: an Overview,” Stroock Special Bulletin, March 30, 2020
• Co-author, “Navigating Coronavirus: A Guide for REIT General Counsel,” Lexis Practice Advisor, March 2020
• Co-author, “Stroock’s Deep Dive Into the Final QOZ Regulations,” Stroock Special Bulletin, January 2, 2020
• Co-author, “The Latest Proposals on Qualified Opportunity Zone Businesses,” TaxStringer, November 4, 2019
• Co-author, “Opportunity Zones for Operating Businesses,” Stroock Special Bulletin, August 7, 2019
• Co-author, “Final Regulations Confirm the Change to the ‘Deemed Dividend’ Tax Regime and Should Shape Your Thinking on Financing/Collateral Arrangements,” Stroock Special Bulletin, June 12, 2019
• Co-author, “Anatomy of a Green QOZ: Tax Strategies for Renewable Energy Investing,” Stroock Special Bulletin, May 6, 2019
• Co-author, "How Qualified Opportunity Zones Can Spark Green Energy," POWER, May 1, 2019
• Co-author, “They’re Out! Stroock’s Take on the Second Set of Proposed QOZ Regulations,” Stroock Special Bulletin, April 19, 2019
• Co-author, “A Model of Complexity and Uncertainty: Redemptions of Partnership Interests,” American Bar Association, December 21, 2018
• Co-author, “Additional Credit Support: How Changes to the ‘Deemed Dividend’ Tax Regime Should Shape Your Thinking on Financing/Collateral Arrangements,” Stroock Special Bulletin, November 12, 2018
• Co-author, “Six Burning Questions on the New Qualified Opportunity Zone Guidance,” Stroock Special Bulletin, November 6, 2018
• Co-author, “The Impact of the Tax Reform Act on the Insurance Industry,” AIRROC Matters, Spring 2018
• Co-author, “Five Provisions of the Tax Reform Act That Will Affect Tax-Exempt Organizations,” Stroock Special Bulletin, January 30, 2018
• Co-author, “Get Out The Backpacks: Carried Interests Must Be Carried For Longer,” Stroock Special Bulletin, January 8, 2018
• Co-author, “The Largest Tax Reform in 30 Years,” Stroock Special Bulletin, December 28, 2017
• Co-author, “The Senate Tax Reform Bill: Benefits for Some and Burdens for Others,” Stroock Special Bulletin, December 7, 2017
• Co-author, “Tax Reform: Now it’s the Senate’s Turn,” Stroock Special Bulletin, November 10, 2017
• Co-author, “Mind Your Own (Unrelated) Business!!” Stroock Special Bulletin, November 7, 2017
• Co-author, “Tax Me Now; Pay Me Later? House Majority Tax Bill Changes to Common Executive Compensation Arrangements and Benefits,” Stroock Special Bulletin, November 6, 2017
• Co-author, “Overview of the Proposed ‘Tax Cuts and Jobs Act’ and How it Differs from Current Law,” Stroock Special Bulletin, November 6, 2017
• “A Snapshot Of Baucus’s Vision For Energy Tax Incentives,” Law360, January 4, 2014
• Co-author, “Time for a NOLs Refresher,” New York Law Journal, June 28, 2010
• “Characterization of Income: Compensation vs. Dividends,” Tax Notes, June 1, 2004, Vol. 103, No. 12

New York; California

J.D., Harvard University, 2003

B.A., Stanford University, 1999