Below is a representative sample of engagements handled by the firm. Specific clients and matters are described in general terms only, consistent with applicable confidentiality and privilege obligations.

REAL ESTATE TAX PLANNING & STRUCTURING

• Federal income tax planning for sponsor and limited-partner positions in real estate investment funds, including fund-level entity selection and exit structuring, on behalf of Wall Street venture capital firms and real estate investment funds.
• Tax due diligence on three real estate investment trust initial public offerings, including detailed examination of activity-grouping, REIT income and asset testing, and operator-level passive activity considerations.
• Partnership tax counsel to owners of a hotel investment company on complex partnership tax matters during the initial public offering of shares as a real estate investment trust, resulting in a successful IPO.
• Formation of U.S.-based private equity real estate funds, including domestic funds for the acquisition of residential properties, with deal sizes ranging from $1 million to $50 million.
• FIRPTA representation across all sides of foreign investment in U.S. real estate, including foreign sellers in dispositions, foreign buyers structuring acquisitions, and U.S. withholding agents on compliance. Regular preparation and filing of Forms 8288, 8288-A, and Form 8288-B withholding certificate applications.
• Cost segregation analysis, building-component, and FF&E classification for development and acquisition projects.
• § 469 passive activity loss planning for high-net-worth investors, including analysis under the § 469(c)(7) real estate professional rules and the seven-day average rental exception of Treas. Reg. § 1.469-1T(e)(3)(ii)(A).
• Tax planning consultation to a multinational professional services firm regarding complex tax matters affecting various investment fund clients.

INTERNATIONAL TAX

• Inbound structuring for foreign individuals, families, corporations, and funds acquiring U.S. real estate and U.S. business interests, including choice-of-entity analysis, FIRPTA structuring, U.S. estate tax planning for non-resident aliens, and treaty positions.
• Outbound structuring for U.S. individuals, families, investors, funds, sponsors, and operating businesses acquiring or holding foreign real estate and foreign business interests, with geographic focus on European Union countries and additional work in Latin America and the Caribbean.
• Application of U.S. anti-deferral regimes — Subpart F, GILTI, PFIC, and CFC analysis — to real estate-holding entities and offshore investment structures.
• Foreign tax credit planning, including FTC limitation analysis under § 904 and creditability of foreign taxes.
• International tax compliance — preparation and filing of Forms 5471, 5472, 8865, 8938, 8621, 3520, 3520-A, FinCEN Form 114 (FBAR), and supporting foreign tax credit returns.

TAX CONTROVERSY

• Representation of businesses and high-net-worth individuals in multiple multi-million-dollar tax controversy matters at both the federal and state levels, across the country, involving income tax, partnership tax, and sales-and-use tax issues.
• Representation before the Internal Revenue Service in audits, examinations, appeals, and related disputes.
• Representation before state taxing authorities in audits, examinations, and appeals on income tax and sales-and-use tax matters.
• Defense of a surviving spouse against a $1 million federal tax lien filed against jointly-owned residential real property of the spouse and her deceased husband. The Internal Revenue Service released the lien.
• Defense of a Martha’s Vineyard restaurant owner against an approximately $1 million state assessment of personal liability for sales-and-use and income tax obligations of the underlying business.
• Defense of partnership and real estate tax positions, with particular depth in technical issues including § 469 passive activity classification, partnership allocations, and basis questions.

TAX CONSULTING TO OTHER COUNSEL

• Engaged by counsel in a high-net-worth matrimonial dissolution to perform forensic tax and valuation analysis. Identified a marital asset that had been undervalued by approximately $250 million.
• Provided international tax structuring analysis to lead counsel in a high-net-worth matter, increasing the client’s net settlement by approximately $5 million.

REAL ESTATE TRANSACTIONS & DEVELOPMENT

• Representation of developer in the acquisition, financing, development, and sale of multiple multifamily housing projects throughout the Southeastern United States.
• Representation of developer in the planning, financing, permitting, construction, and sale of a successful downtown luxury condominium project involving complex environmental and site-remediation issues.
• Representation of client in obtaining the certificate of occupancy for a $40 million, 200-unit apartment complex in Boca Raton, Florida.
• Representation of developer in eminent domain matter using a novel jurisdictional technique to move the case to a favorable forum, resulting in a substantial settlement.
• Negotiation of acquisition, construction, and permanent financing across the capital stack, including C-PACE assessment financing structures.

APPELLATE & SIGNIFICANT MATTERS

• Won reversal at the United States Court of Appeals for the First Circuit on a constitutional question of federal habeas procedure in Donovan v. Massachusetts Parole Board, No. 23-1810 (1st Cir. Dec. 23, 2025), with significant implications for federal review of juvenile sentencing under Miller v. Alabama and its progeny.
• Pro bono representation of a defendant sentenced to life without the possibility of parole as a juvenile. The firm investigated the history of the case, interviewed the original witnesses for the prosecution, discovered Brady violations, presented newly discovered evidence to the court, and filed motions to correct the sentence and for a new trial applying recent Supreme Court decisions. After twenty-three years, the client was released from prison.