John MacMaster, a partner in the Atlanta and New York City offices of Nelson Mullins Riley & Scarborough LLP, is experienced in a wide variety of U.S. tax matters. Recent assignments have involved cross-border tax planning, especially inbound portfolio investment and direct investment in U.S. real estate in light of the Foreign Investors Real Property Tax Act (“FIRPTA”).
More generally, John has dealt extensively with tax matters related to REMICs, real estate investment trusts (REITs), partnerships, charitable organizations, and mergers and acquisitions, while representing clients in a variety of industries including banking, real estate, energy, healthcare, hedge funds, private equity, state and local governmental entities, as well as high net worth non-U.S. individuals.
- University of Wisconsin School of Law, JD, with honors
- Cornell University, College of Arts & Sciences, BA
- Cornell University, College of Engineering
- New York
- U.S. Domestic
- Advised an Iowa-based electrical services company on novel triangular merger among three publicly-held utilities
- Counsel to a major U.S. electric utility on the disposition of its independent power subsidiaries and generating assets
- Advised a major U.S. pension plan on tax matters related to its alternative investments in hedge and private equity funds
- Structured and rendered legal support on U.S./Canada securities offerings and other investments.
- Advised a British public company on the (earnings stripping) recapitalization of its U.S. group.
- Advised a Canadian company on U.S. tax consequences from cross-border energy/commodity swap transactions.
- Tax Controversies
- Controversy counsel for a financial institution in a Voluntary Closing Agreement Program procedure related to blind pool tax-exempt financing
- Controversy counsel for various governmental units in IRS examinations related to arbitrage and other tax-exempt bond matters
- Financial Transactions
- Tax counsel to a peanut processing entity and to a private four-year college on new market tax credit transactions
- Counsel to a Memorial Sloan Kettering Cancer Center in its offering of $300 million tax-exempt synthetic floating rate tax-exempt bonds, with specialized defeasance feature
- Advised Long Island Lighting Company in connection with selected corporate tax aspects of the transfer of its electric properties to Long Island Power Authority (LIPA) and the qualification of LIPA as an IRC Section 115 instrumentality
Previous Professional Experience:
- Partner, Atlanta office of two international law firms (2000-2009; 2009-2017)
- Counsel, New York based law firm (1984-1999)
- Assistant Branch Chief, Office of Chief Counsel (Legislation and Regulations Division), Internal Revenue Service, Washington, D.C.
- American Bar Association
- International Fiscal Association
- New York State Bar Association
- German American Chamber of Commerce
Rate : $$$