Michael Kuczynski Email & Phone Number

Atlanta, Georgia, United States

• Act as outside tax counsel for various nonprofit organizations, helping to advise on federal, state, and local tax considerations.
• Successfully applied for tax-exempt status and reclassification of tax-exempt status through the Forms 1023 and 8940 for various organizations.
• Created corporate structures to help organizations comply with federal tax-exempt laws and avoid unrelated business income.
• Drafted and reviewed joint venture operating agreements to comply with federal tax-exempt laws and avoid unrelated business income.
• Advise on and perform due diligence related to tax-exempt questions in multiple member substitutions by tax-exempt healthcare organizations.
• Advised on corporate structure to enable organizations to benefit from property tax exemptions.

Atlanta, Georgia, United States

• Led tax team for largest health system in Georgia, comprised of 18 hospitals, over 300 physician practices, 3 foundations, and over 30,000 employees.
• Served as the sole in-house tax attorney and 501(c)(3) tax subject matter specialist, advising on acquisitions, contributions, grants, compensation, corporate policies, Section 501(r) compliance, and other financial.
• Prepared annual Forms 990, 990-T, 1120, 1065, and state returns for over 25 entities.
• Led internal reorganization to maximize structure efficiencies and generate tax savings through use of net operating loss carry-forwards.
• Provided due diligence consulting in both pre and post-acquisition integration and structuring. Prepared tax-exemption applications and consulted with IRS.
• Evaluated corporate activities for unrelated business income, including joint ventures, rent agreements, debt-financed property, lab services, and research agreements, assessing which legal entity should engage in.

Greater Atlanta Area

Atlanta, GA

• Conducted mock audit for tax-exempt healthcare system's compliance with Section 501(r) Affordable Care Act requirements.
• Managed multiple teams in preparation of Forms 990, 990-T, Form 5500, foreign filings, and state tax returns for a variety of not for profit healthcare systems, universities, pension trusts, VEBA trusts, and public.
• Analyzed business activities and drafted legal memoranda outlining whether various activities constitute unrelated business income.
• Prepared and submitted Forms 1023 and 1024 request for tax-exemption.
• Reviewed tax documents in support of Ernst & Young’s Tax-Exempt audit practice.
• Led tax consulting projects involving executive compensation, Section 501(r) compliance, grant making procedures, research activities, and tax-exempt bond monitoring.

Atlanta, Georgia

• Analyzed international tax implications of M&A activity, highlighting tax implications for post-merger structure.
• Analyzed foreign withholding tax filings and requirements.
• Researched various topics relating to the Internal Tax Code and international tax treaties and drafted memoranda establishing conclusions of tax positions.
• Reviewed U.S. international tax filings, including Form 5471 and Form 8858.
• Created excel work papers and slide decks to analyze various topics, including FIRPTA, proposed restructurings, withholding tax and foreign tax pools.

Atlanta, Georgia

• Led tax consulting projects involving executive compensation, Section 501(r) compliance, grant making procedures, research activities, and tax-exempt bond monitoring.
• Reviewed staff-prepared tax returns, including the Form 990, Form 990-T, Form 5471, Form 8858 and various state corporate filings.
• Analyzed partnership and alternative investment K-1 returns for unrelated business taxable income, foreign filings and state tax liability.
• Drafted legal memoranda outlining tax positions.
• Drafted Tax Alerts for clients and firm-wide correspondence, which discussed hot button topics relating to tax-exempt entities.
• Was a member of the firm's tax-exempt bond team, which helped to analyze documentation, use and workpapers for compliance with tax-exempt bond rules.

Atlanta, Georgia

• Conducted research and drafted memorandum and opinion letters on various issues involving the Internal Revenue Code.
• Reviewed financial statements and created work papers to verify accuracy of financial data.
• Prepared and reviewed tax and informational filings, including federal Form 990, Form 990-T, Form 5471, Form 8858 and various state corporate and tax-exempt returns.
• Drafted disclosures for compliance with Section 501(r) and the Affordable Care Act.

Llm In Taxation, International Business, Trade, And Tax Law, Book Award For Highest Grade, International Tax Law

Jd

Masters In Accounting- Tax

Bsm, Finance, Legal Studies Of Business