Our team draws upon its in-depth experience to provide creative and thoughtful advice on sophisticated tax matters relating to mergers and acquisitions, private equity and real estate transactions, bankruptcy and insolvency restructurings, private funds, REITs, partnerships and joint ventures, commodities and derivatives, securitizations and insurance company products.
We are an integral part of our corporate and private funds teams, advising on mergers, acquisitions, internal corporate restructurings, fund formations and private equity transactions. We advise on structuring complex onshore and offshore funds for all classes of U.S. and non-U.S. investors investing in a variety of asset classes, including real estate, infrastructure, credit, distressed debt and insurance, commodities and energy products. We also assist our commodities and derivatives and insurance teams in structuring financial products, corporate acquisitions and internal reorganizations.
Partnering with our real estate team, we advise on the tax implications and structuring of real estate transactions. We advise on acquisitions, exchanges (taxable and tax-free), dispositions, joint ventures, commercial real estate leases, partnership tax issues and joint venture arrangements. We also specialize in REIT formation and qualification, as well as acquisitions, dispositions and other transactions involving REITs. In addition, we advise individuals, U.S. pension plans and other tax-exempt institutions, and non-U.S. investors, including foreign governments and qualified foreign pension funds, on structuring their real estate investments to mitigate exposure to tax and tax-filing obligations relating to UBTI and FIRPTA.
We collaborate with our financial restructuring team on high-profile reorganizations and workouts, equity and debt financings and restructurings. Our team regularly advises on structuring transactions to minimize the impact of debt cancellation income and limitations on net operating losses, preserving tax assets and maximizing the tax benefits available to a distressed company following its restructuring.
FOCUS ON
Learn MoreTax Reform Act: What You Need to Know.
In The Spotlight
News
Back To Service-
March 7, 2019 | Financial Times’ Agenda
Austin Lilling Quoted in Financial Times’ Agenda
-
October 29, 2018 | Real Estate Finance & Investment
Mayer Greenberg Quoted in “New Guidelines Clear Up Some OZ Ambiguity”
-
August 8, 2018
Stroock Grabs Executive Compensation Leader Austin Lilling in New York
-
May 3, 2018
Stroock Ranked in 11 Practice Areas by Chambers USA 2018; 29 Leading Lawyers Recognized
-
April 27, 2018 | The Deal
Micah Bloomfield quoted in “IRS Delays New Life Settlement Reporting Requirements”
-
April 24, 2018 | Euromoney Legal Media Group
Michelle M. Jewett Recognized by Euromoney LMG Americas Women in Business Law for Best in Tax
-
March 16, 2018
Stroock Represents Ridgewood Infrastructure in Sale of Neptune Regional Transmission System
-
January 3, 2018
Stroock Represents Carr Properties in Convertible Debt Investment by Clal Insurance Enterprises Holdings Ltd.
-
December 5, 2017
Stroock Advising Atlas Merchant Capital as Co-Lead Investor in $2 Billion Acquisition of Talcott Resolution from The Hartford
-
December 4, 2017 | The Deal
Micah Bloomfield quoted in "Life Settlement Tax Provisions Pass Senate"
-
December 4, 2017 | Law360
Stroock deal team mentioned in "Hartford Sells Life Insurance Business For $2.05B"
-
November 10, 2017 | The Deal
Micah Bloomfield quoted in "Senate Tax Reform Proposal Includes Measure Sought by Life Settlement Market"
-
September 21, 2017 | Commercial Observer
Mayer Greenberg quoted in "DC Is Talking About Reforming the Tax Code—but What Will It Mean for Real Estate?"
-
June 2, 2017
Stroock Receives High Honors in 13 Practices from The Legal 500 United States 2017: 37 Stroock Attorneys Recognized
-
June 1, 2017
Stroock Earns Top Tier Rank in 11 Practices by Chambers USA 2017: 30 Leading Attorneys Recognized
-
May 23, 2017 | Financial Advisor
Kevin Matz quoted in "Little Tax Plan Promises Big Benefits For Wealthy Clients"
-
March 16, 2017 | New York Law Journal
Michelle M. Jewett featured in "On the Move"
-
March 16, 2017 | Real Estate Weekly
Michelle M. Jewett featured in "Who’s News"
-
March 14, 2017 | Law360
Michelle M. Jewett featured in "Stroock Hires Ex-Morrison & Foerster Tax Partner"
-
March 11, 2017 | Global Banking & Finance Review
Michelle M. Jewett featured in "Stroock’s Tax Practice Adds Noted Transactional Advisor Michelle M. Jewett as Partner in New York"
-
March, 9, 2017
Stroock's Tax Practice Adds Noted Transactional Advisor Michelle M. Jewett as Partner in New York
-
October 18, 2016 | Board IQ
Nicole M. Runyan and Jonathan S. Kusko quoted in "Proposed Tax Rule Asks: Is Your Commodity a Security?"
-
May 27, 2016
Stroock Ranked By Chambers USA For 2016
-
August 17, 2015
45 Stroock Partners and Counsel Named to Best Lawyers in America for 2016
-
May 26, 2015 | Law360
Daniel Martinez quoted in "5 Considerations For Banks Eyeing EB-5 Bridge Lending"
-
June 25, 2014
Stroock Attorneys and Practices Ranked by The Legal 500 United States 2014
-
August 5, 2010
17 Stroock Attorneys Named to 2011 Edition of Best Lawyers
-
April 3, 2008
Capital Markets Crisis Group Expansion
-
October 17, 2007
Stroock Represents a JPMorgan Infrastructure Fund in Acquisition of Southern Water
-
July 31, 2007
Stroock Counsels Board of Directors of Monmouth Capital in Merger with Monmouth Real Estate Investment Corporation
-
September 28, 2006
Stroock Represents Arrowpoint Capital Corp. in Management Buyout of Royal & Sun Alliance USA
Publications
Back To Service-
April 18, 2019 | Alternative Investments Quarterly
Will Qualified Opportunity Funds Cannibalize the 1031 Industry?
-
April 15, 2019 | Stroock Special Bulletin
New York Retroactively Reinstates Its Estate Tax Clawback for Certain Taxable Gifts Made Within 3 Years of Death
-
December 28, 2018 | Stroock Special Bulletin
GAAP Updates Affecting Credit Documents: New Revenue Recognition and Lease Accounting Standards
-
November 12, 2018 | Stroock Special Bulletin
Additional Credit Support: How Changes to the ‘Deemed Dividend’ Tax Regime Should Shape Your Thinking on Financing/Collateral Arrangements
-
November 6, 2018 | Stroock Special Bulletin
Six Burning Questions on the New Qualified Opportunity Zone Guidance
-
October 19, 2018 | Stroock Special Bulletin
Stroock’s Take on the New ‘Qualified Opportunity Zone’ Guidance
-
Summer 2018 | Real Estate Finance Journal
“Proposed Revisions to the Volcker Rule’s Implementing Rules — Select Proposals and Open Questions”
-
August 28, 2018 | Stroock Special Bulletin
“Qualified Opportunity Funds: Tax Strategies and Opportunities for Real Estate and Other Investors”
-
August 1, 2018 | TaxStringer
“When Opportunity Knocks to Defer Tax on Gains: ‘Qualified Opportunity Funds’”
By: Kevin Matz -
July 24, 2018 | Stroock Special Bulletin
“Securities and Tax Classifications of Cryptocurrency Relating to ICOs”
-
July 17, 2018 | Stroock Special Bulletin
“When Opportunity Knocks to Defer Tax on Gains – ‘Qualified Opportunity Funds’”
-
July 2, 2018 | Stroock Special Bulletin
“Proposed Revisions to the Volcker Rule’s Implementing Rules – Select Proposals and Open Questions”
-
June 18, 2018 | Stroock Special Bulletin
“The Lender Case: Potential Avenue for Family Offices to Obtain Trade or Business Expense Deductions for Rendering Investment Management Services”
By: Kevin Matz -
Spring 2018 | AIRROC Matters
“The Impact of the Tax Reform Act on the Insurance Industry”
-
April 11, 2018 | Stroock Special Bulletin
“Three Key Federal Income Tax Issues Raised by Cryptocurrencies”
-
March 16, 2018 | WealthManagement.com
"Pass-Through Deduction Primer"
By: Kevin Matz -
March 2, 2018 | WealthManagement.com
"Gifting Opportunities Under the New Tax Law"
By: Kevin Matz -
February 13, 2018 | Stroock Special Bulletin
"The Impact of the Tax Reform Act on the Insurance Industry"
-
February 1, 2018 | TaxStringer
"How the 2017 Tax Reform Act Affects Estate Planning for High-Net Worth Individuals"
By: Kevin Matz -
January 30, 2018 | Stroock Special Bulletin
"Five Provisions of the Tax Reform Act That Will Affect Tax-Exempt Organizations"
-
January 8, 2018 | Stroock Special Bulletin
"Get Out The Backpacks: Carried Interests Must Be Carried For Longer"
-
December 28, 2017 | Stroock Special Bulletin
"The Largest Tax Reform in 30 Years"
-
December 7, 2017 | Stroock Special Bulletin
“The Senate Tax Reform Bill: Benefits for Some and Burdens for Others”
-
November 10, 2017 | Stroock Special Bulletin
“Tax Reform: Now it's the Senate's Turn”
-
November 6, 2017 | Stroock Special Bulletin
“Tax Me Now; Pay Me Later? House Majority Tax Bill Changes to Common Executive Compensation Arrangements and Benefits”
-
November 6, 2017 | Stroock Special Bulletin
“Overview of the Proposed 'Tax Cuts and Jobs Act' and How it Differs from Current Law”
-
August 1, 2017 | Stroock Special Bulletin
"Eight Regulations the IRS Says Are “Unduly Complex,” Impose “an Undue Financial Burden on Taxpayers” or Exceed the IRS’s Statutory Authority"
-
February 21, 2017 | Stroock Special Bulletin
"President Trump’s Tax Plan to be Revealed Soon – Where Do We Stand Today?"
-
January 5, 2017
"Investment Management and Related Practices: Compendium of Articles Published in 2016"
-
November 18, 2016 | Stroock Special Bulletin
"New IRS Partnership Regulations Shut Down Bottom Guarantees and Significantly Limit Use of Leveraged Partnerships"
-
October 5, 2016 | Stroock Special Bulletin
"IRS Issues New 'No Rule' Area and Related Proposed Regulations: Potential Implications for Regulated Investment Companies"
By: Mayer Greenberg -
August 31, 2016 | Stroock Special Bulletin
"Treasury Department Finalizes Definition of Real Property for Real Estate Investment Trusts (REITs)"
-
August 25, 2016 | Stroock Estate Planning Alert
"New Proposed Treasury Regulations Imperil Valuation Discounts for Family Controlled Entities"
-
January 13, 2016
"When Is Your Tax Return a False Claim to the Government?"
-
November 18, 2015
"Bipartisan Budget Act Requires Partnerships to Share a Portion of the Audit Burden"
-
October 19, 2015 | roock Special Bulletin
"IRS Releases 871(m) Final Regulations – New Tests for Dividend Equivalents"
-
July 28, 2015 | Stroock Special Bulletin
"D.C. Circuit Court Rules Sec. 4371 Federal Excise Tax Does Not Apply to Foreign-to-Foreign Retrocessions"
-
July 9, 2015
"New York City Releases 2015/16 Real Estate Tax Rates"
-
October 2014
REIT Conversions
-
June 12, 2013
"Good Things Come to Those Who Wait: The Section 336(e) Regulations Finally Finalized"
-
March 20, 2013
“Piercing the Political Veil: Disclosure of Corporate Spending”
-
March 15, 2013
"A Tale of Two PACEs: Commercial Success vs. Residential Repose"
-
February 15, 2013
“The Final FATCA Regulations: A Crib Sheet”
-
February 14, 2013
"Renewables Renewed"
-
January 8, 2013
"Key Tax Provisions of the Fiscal Cliff Deal"
-
August 7, 2012
"Gunboat Diplomacy? Treasury Releases Model FATCA Intergovernmental Agreement"
-
February 3, 2012
"Mortal or Venial? Section 871(m) and the Seven Deadly Sins of Equity Swaps"
-
November 29, 2011
"IRS Proposes Regulations on Sovereign Investments"
-
September 16, 2011
IRS Proposes Regulations Addressing Notional Principal Contracts and Section 1256 Contracts
-
July 26, 2011
"New IRS Notice Relaxes FATCA Compliance Timeline in Response to Taxpayer Concerns"
-
April 2011
"REITs Overview"
-
April 2011
"REITs: Common Pitfalls and Fixes Checklist"
-
January 10, 2011
Tax Credits – What’s Out There
-
September 2010
"Property Assessed Clean Energy (PACE): Emerging Technique for Financing Energy Efficiency Encounters New Obstacles"
-
July 21, 2010
"Health Care System Overhaul: Tax Code Changes"
-
June 29, 2010
“Congress Works to Close Carried Interest ‘Loophole’”
-
April 21, 2010
“The Thirty Percent Solution? FATCA Provisions of the HIRE Act”
-
March 1, 2010
"IRS Grants Certain Taxpayers an FBAR Filing Deadline Extension to June 30, 2011"
-
December 2009
“The Shape Of Things To Come? Accounting, Regulatory, and Other Developments That May Affect Recovery In The Securitization Markets”
-
October 15, 2009
"The Shape of Things to Come? Accounting, Regulatory and Other Developments that May Affect Recovery in the Securitization Markets"
-
September 17, 2009
“New Treasury Guidance Eases and Clarifies Limitations on Modifications of Commercial Securitized Mortgages”
-
September 9, 2009
“Hidden Implications of Revenue Ruling 2009-25 for Life Settlements”
-
June 25, 2009
“IRS Grants Certain Taxpayers an FBAR Filing Deadline Extension to September 23, 2009”
-
June 24, 2009
“FBAR Filing Deadline is June 30, 2009”
-
May 15, 2009
“Treasury Department Releases Latest Green Book: What’s in Store for Private Funds Investors and Managers”
-
May 11, 2009
“New IRS Revenue Rulings: Amount and Character of Income on Life Insurance Contracts”
-
April 2009
“Tax Implications Of Proposed Stop Tax Haven Abuse Act”
-
April 2009
"Will Commercial Real Estate Benefit From the Financial Stability Plan and the Stimulus Act?"
-
March 17, 2009
"New Revenue Procedure and Revenue Ruling Issued by IRS: Tax Deductions for Theft Loss"
-
March 5, 2009 | Stroock Special Bulletin
Tax Implications of Proposed “Stop Tax Haven Abuse Act”
-
February 19, 2009
“Will Commercial Real Estate Benefit from the Financial Stability Plan and the Stimulus Act?”
-
February 17, 2009
“The American Recovery and Reinvestment Act of 2009: An Overview of its Renewable Energy and Energy Efficiency Provisions”
-
January 2009
"New York State 2008 Tax Law Changes Affect LLC and LLP Filings Due By January 30th For Calendar Year Filers"
-
January 2009 - Vol. 2, No. 2
"Practical Tax Issues Related to Theft Losses from Ponzi Schemes"
-
December 31, 2008
"Deductibility of Losses in a Ponzi Scheme"
-
August 2008
“Housing Act of 2008 Liberalizes REIT Rules”
-
Summer/Fall 2008
“Turmoil Creates Buying Opportunities for Foreign Investors”
-
December 2007
“Long-Awaited Legislation Relaxes Tests for Qualification as a Code Section 216 Housing Cooperative,”
By: Richard Siegler -
October 29, 2007
“Master Class: The Re-emergence of Master Limited Partnerships for Financial Assets”
-
March 2007
“New York’s Department of Taxation Concludes ERISA Doesn’t Preempt New York State’s Tax on UBTI”
-
August 5, 2006
"Pension Protection Act of 2006: Congress Makes it Easier to Satisfy the ERISA Plan Assets Regulation 25% Limit and Provides Much Needed Relief From Certain of the Prohibited Transaction Rules Under ERISA and the Code"
By: Abbey L. Keppler -
July 5, 2006
"Second Circuit: ERISA Does Not Preempt California’s Tax On UBTI"
-
June 2006
"Does the Bank Loan Exception Apply to Non-U.S. Banks that Pledge Cash Collateral in Derivative Transactions?"
-
November 11, 2005
"IRS Issues Long-Awaited Proposed Regulations under Section 409A of the Internal Revenue Code"
By: Abbey L. Keppler -
March 2, 2005
"IRS Releases Guidance on Section 409A Transition Rules"
-
August 2, 2004
"Implications of New U.S.-Japan Income Tax Treaty for Intellectual Property Licenses"
-
July 25, 2003
"IRS Provides Guidance on the Application of Private Activity Bond Tests to Refunding Issues"
-
May 28, 2003
"Summary of Jobs and Growth Tax Relief Reconciliation Act of 2003"
-
April 25, 2003
IRS Provides Guidance on Tax Treatment of World Trade Center Grant Program Payments
-
July 1, 2002
IRS Issues New Proposed Regulations on Golden Parachute Payments
-
May 10, 2002
$700 Million Plan Announced for Redevelopment and Revitalization of Lower Manhattan
-
March 15, 2002
President Bush Approves Economic Stimulus Package With over $5 Billion to Aid Reconstruction in New York City and Other Significant Business Tax Incentives
-
Summer 2001
Congress Passes Broad Estate, Gift and Generation-Skipping Tax Changes
-
May 2001
"How to Get Swap Counterparty Investment Discretion in CAT Bond Transactions"
Events
Back To Service-
May 23, 2019
NYSSCPA's Annual Estate Planning Conference
-
March 7, 2019
Highlights of 2019 Heckerling Institute on Estate Planning
-
February 25, 2019
New York Tax Study Group Meeting
-
February 13, 2019
Structuring Redemptions of Partnership and LLC Interests: Issues Unique to Liquidating Distributions
-
January 15, 2019
NYSSCPA/FAE - Taxation of Financial Instruments and Transactions Conference
-
December 4, 2018
Queens/Brooklyn Chapter Annual Tax Conference
-
November 14, 2018
REITs: Developments in REIT Conversions, FIRPTA and the 2017 Tax Reform Act
-
November 8, 2018
Family Office Symposium
-
November 5, 2018
NYSSCPA's Tax Planning for Individuals Conference
-
October 18, 2018
Tax Planning under the Tax Cuts and Jobs Act of 2017
-
September 26, 2018
Tax Reform - Significant Changes for the Energy Industry
-
May 22-23, 2018
Financial Research Associates' The Private Investment Fund Tax Master Class
-
May 9, 2018
Strafford's Partnership Tax: Planning, Accounting, Reporting and Tax Reform Seminar
-
November 8-10, 2017
FRA's Private Investment Fund Tax and Accounting
-
August 22, 2017
U.S. Estate and Gift Taxation of Nonresident Aliens
-
June 14, 2017
Structuring Redemptions of Partnership and LLC Interests: Navigating Issues Unique to Liquidating Distributions
-
June 8, 2017
All About REITs In The Private Funds World
-
March 1, 2017
Strafford's Real Estate Joint Ventures Seminar
-
March 17, 2016
Strafford Publications Webinar "REITs: Developments in REIT Conversions, FIRPTA and Other Changes in the Tax Extenders Bill"
-
July 14th, 2015
Clear Law Institute's Webinar "REITs: Critical Tax Considerations"
-
March 13, 2015
ISDA's Understanding Tax Related Provisions of the ISDA Master Agreement
-
June 17-18, 2014
IIB's Annual Tax Seminar
-
September 20, 2010
REBNY Law and Real Estate Graduate Course
-
July 15, 2010
Form 990 Seminar
-
Monday, September 14 - Wednesday, September 16, 2009
DealFlow Media's Life Settlements Conference 2009
-
Tuesday, May 19, 2009
The Structured Finance Institute’s U.S. Tax Advantaged Structures for Investing in Distressed Debt
-
Friday, May 8, 2009
Stroock Event - 2009 Power Industry Developments
-
October 14, 2008
Stroock Audio Conference: "The Emergency Economic Stabilization Act of 2008: Opportunities and Challenges"
-
December 10-11, 2007
How to Advise Entrepreneurial Clients: What Every Counsel Should Know
-
May 11, 2007
2007 Power Industry Developments
-
Tuesday, April 17 – Thursday, April 19, 2007
ISDA® 22nd Annual General Meeting
-
Monday, December 4-5, 2006
ICI 2006 Securities Law Developments Conference
-
Tuesday, March 14 - Thursday, March 16
ISDA 21st Annual General Meeting
-
November 13, 2003
"COMING TO AMERICA - Practical Tax and Benefit Planning Strategies for In-Bound Executives"
Lawyers In This Group
Back To Service| Name | Title | Office |
| Brian J. Senie | Associate |
New York 212-806-5928 (Office) bsenie@stroock.com |
| Mitchell Snow | Associate |
New York 212-806-5605 (Office) msnow@stroock.com |
| Mark A. Levy | Senior Counsel |
New York 212-806-6062 (Office) mlevy@stroock.com |
| Austin S. Lilling | Partner |
New York 212-806-1244 (Office) alilling@stroock.com |
| Michelle M. Jewett | Partner |
New York 212-806-5835 (Office) mjewett@stroock.com |
| Micah W. Bloomfield | Senior Counsel |
New York 212-806-6007 (Office) mbloomfield@stroock.com |
| Jeffrey D. Uffner | Partner |
New York 212-806-6001 (Office) juffner@stroock.com |
| Mayer Greenberg | Partner |
New York 212-806-6286 (Office) mgreenberg@stroock.com |
| Daniel Martinez | Associate |
Miami 305-789-9306 (Office) dmartinez@stroock.com |
