Cases
Experience: Business Entities: U.S. Planning: Represented Carbyne Ltd., an Israeli-founded public safety technology company, in connection with tax matters related to its $625 million all-cash sale to Axon Enterprise, Inc.
Represented a hedge fund management company in connection with a capital investment by a leading private equity firm.
Represented an insurance brokerage firm in connection with the design
implementation of life insurance premium finance
life settlement programs.
Represented the promoter of tax favored investments with respect to IRS audits challenging in excess of $1 billion of allegedly fraudulent income tax deductions.
Represented the bankruptcy trustee in Peregrine Financial Group, Inc. in connection with alleged income tax deficiencies arising from embezzled income.
Structured a transaction for a not-for-profit organization to exercise subscription rights in connection with the demutualization of an insurance company where capital stock was provided by a board member of the organization. The transaction was complex in that it needed to be completed in a manner that complied with applicable laws regulating not-for-profits while avoiding the creation of unrelated business taxable incomes
the intermediate sanction rules.
Organized investment pools specializing in tax lien certificates
the origination of residential mortgages in a manner which provided an efficient structure for non-U.S. investors
investors with atypical state income tax profiles.
Represented a not-for-profit entity with respect to corporate governance
not-for-profit issues.
Advised a not-for-profit entity with respect to its exposure to the intermediate sanction rules.
Represented a publicly traded real estate investment trust in its initial public offering
numerous acquisitions
dispositions.
Represented clients seeking private letter rulings from the IRS.
Business Entities: Non-U.S. Planning: Established the tax structure for a publicly traded Florida-based cruise shipping company based out of Liberia
for a privately held Florida-based cruise shipping company based out of Malta.
Structured a commercial mortgage Real Estate Investment Trust.
Structured an Irish Collective Asset Vehicle to hold an interest in a real estate fund, in order to create tax efficiencies for non-US investors.
Represented real estate funds owned in part by sovereign wealth funds.
Designed a tax efficient structure for a U.S. medical supply company in connection with its overseas expansion.
Represented a Swedish company in connection with its U.S. real estate investments.
Implemented an international structure to minimize taxation of intellectual property royalties using a 'Double Irish Dutch S
wich.'
Represented the U.S.-based subsidiary of a multinational hospitality company in connection with entering into a plea agreement with a state tax authority due to claims that the U.S. subsidiary accrued
deducted approximately $100 million of royalty deductions for amounts that were never paid (
never could be paid). This representation included restructuring numerous aspects of the client's business operations in order to obtain U.S. tax compliance.
Advised clients regarding the potential implementation of the Base Erosion
Profit Shifting (BEPS) principles of the Organisation for Economic Co-operation
Development (OECD).
Represented a joint venture between a Korean public company
a U.S. company in connection with a $1 billion joint venture to develop privatized military housing in Seoul.
Represented an internet marketing company based in the U.S. Virgin Isl
s with respect to the tax planning of its owners.
Individual: Non-U.S. Planning: Represented numerous offshore investors in their real estate investments
active U.S. business activities in order to create structures that were both income
estate tax efficient.
Tax planning for non-U.S. citizens prior to their becoming U.S. residents.
Represented taxpayers in connection with their renunciation of U.S. citizenship.
Represented non-U.S. clients with substantial holdings in U.S. stocks
real estate.
Designed trust structures to optimize the use of the fiduciary accounting rules for throwback tax planning.
Designed tax efficient qualified domestic trusts to minimize the eventual estate tax liability of taxpayers who did not have a U.S. spouse.
Individual: U.S. Planning: Established a tax efficient structure for the indirect owner of an Indian high frequency trading firm.
Served as an expert witness in a criminal tax trial involving advisory fees paid to a U.S. trading advisor of a commodity pool.
Tax efficient restructuring of foreign trust holdings for a U.S. family in order to comply with U.S. income tax requirements.
Implemented an estate tax savings strategy using self-canceling installment notes (including the receipt of an IRS closing letter providing 'no change' when the taxpayer passed away less than a year after the transactions took place).
Served as an expert witness in a 'midco' tax shelter case that was docketed for Tax Court (Loudermilk v. Commissioner).
Structured private placement life insurance investments.
Represented a profit sharing plan where the IRS sought to disqualify the plan.
Restructured a controlling shareholder's position in a publicly held company in order for the shareholder's family to take advantage of available estate tax deferral provisions for certain concentrated holdings.
Represented numerous real estate entities whose debts were restructured in tax efficient manners.
Represented numerous taxpayers in like-kind exchange transactions.
Implemented general power of appointment planning for U.S. trusts with low basis, non-generation skipping tax exempt assets.
Advised clients on how to structure their affairs to avoid residency in high tax states.
The above representations were h
led by Mr. Bakal prior to his joining Greenberg Traurig, P.A.
