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Dispute over interpretation of provisions in Tax Allocation Agreement in which Claimant’s position and Respondent’s position differed by approximately $20,000,000. Responsible for Respondent’s initial brief, final brief, direct examination of expert witness and cross-examination of Claimant’s expert witness. The Arbitration Panel unanimously found for Respondent.
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Rendered tax opinion in $14 Billion transaction.
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Drafted allocation, distribution and other financial and tax-related provisions of an LLC agreement (including complicated carried interest) for a joint venture between the retirement system of a state and a TIMO serving as manager. The LLC invested over $150 Million in timberlands to be acquired, developed, managed and disposed of by the entity. Rendered tax opinion required by state retirement system.
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Drafted allocation, distribution and other financial and tax-related provisions of an LLC agreement (including intricate carried interest) for a joint venture among the retirement systems of two states and a TIMO serving as manager. The LLC invested $180 Million in timberlands to be acquired, developed, managed and disposed of by the entity.
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Key member of litigation team representing a major oil and gas exploration and production company and local natural gas distributor in dispute with IRS regarding a change in accounting method for costs of pipeline repairs. IRS issued a $28mm Notice of Deficiency for taxable years 2007 and 2008; reached settlement with government in Tax Court proceedings which resulted in client receiving refunds totaling $856,000.
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Provided federal and international tax advice with respect to the formation of, and offering of interests in, a timber fund by an established timberland investment management organization (TIMO). The fund raised in excess of $400 Million, included both a Delaware fund and a Cayman Islands parallel fund and is comprised of U.S. and international investors, including corporate and public retirement systems, foundations and private investors.
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Provided tax and business planning advice and analysis to a national property development, management, leasing and construction company and its principals in connection with the sale of an interest in a major real estate project to an institutional investor. Drafted allocation, distribution and other financial and tax-related provisions of LLC agreements for a multi-tiered structure holding the project.
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