Long-Short Equity Hedge Fund. Structured formation of a hedge fund group focused on equity value investment, as well as designing and implementing certain related tax-efficient investment strategies. Drafted and reviewed tax aspects of private placement memorandum and limited partnership agreement of fund.
Hybrid Private Equity/Hedge Fund. Assisted the fund and its investment managers in structuring a convertible note investment in a renewable biomass energy company in order to minimize potential adverse tax consequences to the fund and its investors.
International Transactions, Tax Optimization of Business Operations and Estate Planning
Foreign Investment and Estate Planning Advice. Advised high net worth client on reporting and tax implications of certain foreign investments. Advised client to implement CLAT strategy rather than create a charitable foundation in order to achieve charitable goals while optimizing estate-planning benefits.
Entrepreneur. Advised on structuring tax-optimal American retail business strategies, as well as related private equity and consulting businesses and certain year-end tax and estate planning.
M&A Transactions
M&A Tax Advice. Counseled client on the sale of its subchapter S-corporation, taking into account tax rate differentials and potentially adverse implications of cancellation of indebtedness income.
Intellectual Property Tax Optimization and Start-ups.
Startup Co-Founder 83(b) Advice. Advised co-founder of successful startup company regarding best practices to minimize cost of failure to make timely Section 83(b) election prior to sale of company.
Technology Startup and Intellectual Property Optimization. Provided detailed advice and planning recommendations to startup in the ad tech sector considering the relocation of its intellectual property holdings and certain other critical operations offshore.