Analysis and strategic advice relating to high-value real estate inherited via. ownership of S Corporation shares.  Implications of sale of underlying property and distribution of assets on built-in gains and outside capital losses, intra-year netting and carry forward/carry back strategies, historical analysis of inside basis adjustments from date of death forward and implementation of dissolution mechanics to ensure recapture without tax slippage.

Advice and tax structuring relating to the sale of three utility-scale solar projects.  Internal vs. external basis, implications of flip structure involving tax equity involved in sale of primary interests, review of indemnity language, cash grant implications and negotiating tax aspects of $80m transaction.

Structuring and analysis of a multinational services partnership in relation to ECI allocation and US withholding obligations under S. 1446 for non-US partners; advice on timing and procedural application for refund of over-withheld monies with respect to non-US partner.