With the rapid pace of legislative developments in the federal income tax area, the Tax Practice Group places a high priority on monitoring proposed tax changes so that our clients may respond quickly to new legislation. The lawyers in our Tax Practice Group work with lawyers from our other practice groups to develop tax-efficient planning for transactions and business operations. We also represent clients in disputes with the Internal Revenue Service at the audit level, at the appellate level, and in litigation. Our experience also includes requests for private letter rulings from the Internal Revenue Service.
Members of the Tax Practice Group are also skilled at dealing with the special concerns of tax-exempt entities under the Internal Revenue Code. These issues include participating mortgage loans, unrelated business taxable income (particularly as applicable to the acquisition of debt-financed property), prohibited transactions under ERISA, and the Department of Labor's plan asset rules defining real estate operating companies and venture capital operation companies. We are also experienced in organizing and operating REITs, have established 501(c)(25) entities for qualifying clients, and have structured REMICs for our financial institution clients.
Mark S. Munro
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