David provides tax advice to private investment funds, including hedge funds, credit funds, and distressed debt funds, as well as financial institutions, REITs, and real estate, infrastructure, and renewable energy developers and investors.
He also advises private real estate and infrastructure funds, public and private REITs, closely held real estate companies, and non-U.S. real estate and infrastructure investors on matters including mergers and acquisitions, UPREITs, DownREITs, REIT conversions, rollup transactions, debt and equity offerings, bankruptcy and debt workouts, and the U.S. tax implications of real estate-related investments and operations in the United States under the Foreign Investment in Real Property Tax Act (FIRPTA).
Experience
Representative matters
Representative matters
Advised several leading private equity real estate funds on all tax aspects of their fund structures and real estate debt and equity investments, including REIT propco/ opco structures, REIT feeders/ blockers, “baby REIT” and other REIT asset disposition planning, REIT-TMPs, “fractions rule”-compliant joint ventures, REMIC investments and IRC 1031 exchanges.
Advised creditors of CBL & Associates on tax aspects of Chapter 11 bankrupcty, including issues arising under FIRPTA, REIT charter restrictions and tax attribute preservation.
Advise public REITs and property owners on UPREIT and DownREIT transactions, including sophisticated partnership tax structuring and liability allocation planning and negotiation of tax protection agreements.
Advised several leading private equity real estate funds on all tax aspects of their fund structures and real estate debt and equity investments, including REIT propco/ opco structures, REIT feeders/ blockers, “baby REIT” and other REIT asset disposition planning, REIT-TMPs, “fractions rule”-compliant joint ventures, REMIC investments and IRC 1031 exchanges.
Advised creditors of CBL & Associates on tax aspects of Chapter 11 bankrupcty, including issues arising under FIRPTA, REIT charter restrictions and tax attribute preservation.
Advise public REITs and property owners on UPREIT and DownREIT transactions, including sophisticated partnership tax structuring and liability allocation planning and negotiation of tax protection agreements.
Advise public and private REITs on tax structuring in connection with renewable energy investments.
Credentials
Education
Education
- New York University School of Law, 2014, J.D.
- University of California, Berkeley, 2010, B.A., with distinction
Professional admissions & qualifications
Professional admissions & qualifications
- New York