Capital Gains Tax Planning for Real Estate Transactions: Tax Allocations, IRC 338 and 754 Elections, IRC 1031, QOFs

Mr. Sanders focuses his practice in the area of taxation, particularly in matters affecting partnerships, limited liability companies, S-corporations, real estate, tax controversy, and estate planning, including trusts and estates. He also has a large practice in the area of exempt organizations involving healthcare and low-income housing, associations and joint ventures between for-profits and nonprofits, as well as structuring New Markets Tax Credit ("NMTC") and Historic Tax Credit ("HTC") transactions. He is the author of Joint Ventures Involving Tax-Exempt Organizations (3rd Ed., 2007; 4th Ed., 2013) which was recently cited by the majority opinion in the widely covered U.S. Supreme Court decision in Burwell v. Hobby Lobby Stores, Inc. He previously served as an attorney-advisor to the assistant secretary of tax policy at the Office of Tax Legislative Counsel.

Mr. Senie advises clients on tax issues arising in real estate transactions and related transactions involving partnerships, REITs and qualified opportunity zone funds, including mergers, acquisitions, financings, restructurings and fund formation. He has provided counsel for private equity sponsors, publicly traded corporations and REITs in a variety of sectors ranging from multi-family residential, office and retail to lodging, gaming, healthcare and insurance.

Mr. Koegl is a Managing Director in our New York City office and specializes in the real estate industry. He has served clients with a broad mix of operations, including residential, commercial, hospitality, mixed use, infrastructure, real estate backed financial instruments, and construction. Mr. Koegl has experience with public and private REITs, traditional real estate funds, private equity, fund of funds, venture capital, Fortune 500 public companies, inbound and outbound foreign investments, domestic, international, state and local tax compliance, reporting, planning, and structuring. He works closely with his clients to manage tax compliance and analyze, research, discuss, plan, and memorialize tax policy and positions. Mr. Koegl assists clients in planning or reviewing existing client structures for foreign, federal, and state tax expense, exposure, efficiency, and filing requirements. Prior to joining the Firm, he was a senior manager at a Big Four accounting firm in the New York real estate tax practice, where he served public and private clients with a specialization in real estate funds and REITs.