Patrick O'Bryan Email & Phone Number

I have significant experience working with clients on all aspects of their federal income tax needs. I strive to make sure that taxes don’t get in the way of the economic deal and to find innovative solutions to tax issues that meet the client’s financial objectives.I have vast experience advising clients on how to minimize tax liabilities, including a focus on the following areas:I have been on the forefront of investing in Opportunity Zones, having structured deals since the inception of the program and actively helping to navigate the new regulations. We have represented both Fund sponsors to set up their fund to raise money to invest in Opportunity Zones and have represented numerous developers in structuring their project to be OZ compliant.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 exchangesWorking with real estate companies to maximize their ability to receive long-term capital gain treatmentWorking with real estate companies to minimize their state real estate transfer tax liabilitiesWorking with lenders (including distressed debt purchasers) and borrowers to implement structures that minimize the tax consequences of debt workouts, both inside and outside of bankruptcyProviding 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.

Listed skills include Tax Law, Restructuring, Corporate Law, Legal Research, and 1 others.