Raj Tanden is a partner and business lawyer with Foley & Lardner LLP, where he represents clients in corporate and tax matters across a broad spectrum of domestic and cross-border transactions. Mr.
Tanden chairs the firm’s New England and Southern California Tax Practices. Mr. Tanden focuses his practice on investment management transactions and devotes a substantial portion of his practice in assisting U.S. sponsors establish tax-efficient alternative investments funds for non-U.S. and tax-exempt investors.
Mr. Tanden also works on regulated investment companies (mutual funds), renewable energy transactions and health care clients.
Mr. Tanden is a Fellow of the American College of Tax Counsel (ACTC), comprised of the leading 700 tax lawyers nationwide.
Mr. Tanden has received several, innovative Internal Revenue Service (IRS) private letter rulings on behalf of clients, including:
- One of the first rulings that a publicly-registered, non-traded REIT may adopt a “multi-class” structure similar to those used by mutual funds
- Other rulings applicable to REITs, including that a target C corporation may issue a note to distribute out all of its historic “earnings and profits” before its acquisition by a REIT, as long as the target’s historic business and assets would be used to repay the note after the acquisition
- Rulings on behalf of public investment funds, including the following: the first rulings issued by the IRS that an acquiring mutual fund need not retain any assets of a target fund under the “continuity of business enterprise” doctrine; and that cancellation of indebtedness income would constitute qualifying income
- Rulings that taxpayers subject to SEC Rule 144A restrictions on the sale of stock in a publicly-traded company may use the “installment method” for the sale, even though the method cannot be used for publicly-traded property
- Rulings on like-kind exchanges, including the following: a tenant may exchange commercial leasehold interests where a third-party would pay a substantial sum to build out the tenant’s new space (also known as a “build to suit”); and an accommodator would not be disqualified from completing like-kind exchanges for paying a referral fee to brokers who also own equity in the accommodator
Mr. Tanden earned his LL.M. in tax from the New York University (NYU) School of Law (1996) and his J.D. from the University of Southern California (USC) Gould School of Law (1992). His undergraduate degree was conferred by the USC Leventhal School of Accounting (B.S., 1988).
Admissions and Professional Memberships :
Mr. Tanden is admitted to practice in California and Massachusetts.
Mr. Tanden is a member of the Executive Committee of the USC Tax Institute. He is also a member of the Tax Advisory Group of the Investment Company Institute and the Government Relations Committee and Federal Tax Subcommittee of the National Association of Real Estate Investment Trusts. Mr. Tanden has co-chaired the Practising Law Institute (PLI) annual Finance for Lawyers and Other Professionals seminar and is a past chair of the American Bar Association (ABA) Tax Section Investment Management Committee. He has authored numerous articles and regularly speaks for the ABA, American Law Institute (ALI), NYU Federal Tax Institute, PLI and USC Tax Institute.
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