Karl Fryzel

Karl P. Fryzel is Co-Chair of the Firm’s Tax Department and a member of the Private Equity & Venture Capital Group. His practice includes all aspects of tax planning for corporations, partnerships, limited liability companies and individuals engaged in business and investment activities.

Karl handles the tax aspects of venture capital and private equity financings, corporate and partnership restructurings, mergers and acquisitions, general advice in acquiring, holding and disposing of real estate, the formation of investment funds, executive compensation and preparation of tax disclosure materials in private and public offerings of partnership and corporate securities, including investment partnerships and real estate investment trusts.

He has particular experience in advising tax-exempt organizations; in structuring leasing transactions; international tax planning of inbound and outbound corporate and real estate transactions and offshore investment funds; tax planning of debt restructurings for creditors and debtors; tax disputes in administrative and judicial proceedings; and representation of institutional investors and developers of low-income housing credit projects.

After law school, Karl was an attorney-advisor in the IRS Office of Chief Counsel in Washington, D.C. where he drafted international tax regulations and legislation. He also served as an attorney-advisor in the Appellate Section of the Tax Division, U.S. Department of Justice, where he briefed and argued over 50 cases in the U.S. Courts of Appeal and the U.S. Supreme Court. Following his years of government service, Karl has spent over 30 years in private practice in Boston.

Representative Experience :

• Assisted numerous venture capital, private equity and hedge funds in organizing new funds and making investments in portfolio companies.
• Guided numerous public and private companies through tax-free acquisitions in the United States and in cross-border transactions.
• Advised several REIT’s and mutual funds concerning the tax aspects of organization and operations.
• Structured sale-leasebacks and leveraged leases of real estate and equipment in transactions valued at over one billion dollars.
• Assisted healthcare organizations and museums in forming joint ventures with for-profit enterprises.
• Handled numerous IRS and Massachusetts tax audits through the appeals and settlement process, and in court, including cases involving national tax shelter audit teams.

Professional Affiliations :

• Member, American Bar Association – Tax Section
• Member, Boston Bar Association – Tax Section
• Member, Boston Tax Forum

Education :

• J.D., Georgetown University Law Center, 1976
• A.B., summa cum laude, Boston College, 1973
• London School of Economics and Political Science 1971-1972

Admissions : Massachusetts

Admitted To Practice :

• U.S. Tax Court
• U.S. Court of Appeals for the First Circuit