Patrick O’Bryan has significant experience working with clients on all aspects of their federal income tax needs. He strives to make sure that taxes don’t get in the way of the economic deal and works to find innovative solutions to tax issues that meet the client’s financial objectives.
He has vast experience advising clients on how to minimize tax liabilities, including a focus on the following areas:
- Structuring and advising real estate clients throughout the life-cycle of their investment, with significant experience working with public and private REITS (including providing ongoing compliance advice and tax opinions regarding REIT status), private investment funds, and other partnerships and other pass-through vehicles
- Working with clients through the Section 1031 like-kind exchange process, including reverse and construction exchanges
- Working with real estate companies to maximize their ability to receive long-term capital gain treatment
- Working with real estate companies to minimize their state real estate transfer tax liabilities
- Working with lenders (including distressed debt purchasers) and borrowers to implement structures that minimize the tax consequences of debt workouts, both inside and outside of bankruptcy
- Providing tax advice and opinions for tax credit transactions, including LIHTC (low-income housing tax credits), HTC (historic tax credits), NMTC (new market tax credits), ITC (investment tax credits) and PTC (production tax credits)
- Assisting clients with all matters involving the IRS, such as audits and appeals, ruling requests, and negotiating settlements for tax delinquencies.
