Sung H. Hwang focuses on the full spectrum of business tax law, including complex structured financial products, mergers and acquisitions, real estate and real estate investment trusts (REITs), investment management, mezzanine financing, business tax, tax controversies and litigation, private equity, international tax, and multi-partner joint ventures.
Sung also represents tax-exempt organizations. He represents clients before the Internal Revenue Service (IRS), and state and local tax authorities regarding tax ruling requests and audits.
Sung has considerable experience in domestic and cross-border transactions involving real estate partnerships and funds, private equity funds, hedge funds, asset managers, family offices, and financial institutions.
He also has experience with tax credits, including energy-based tax credits. Sung previously worked for the IRS. In addition to his legal career, Sung is an officer in the U.S. Army Reserve and previously served with the New York Army National Guard.
In 2008, he was deployed to Afghanistan with a New York Army National Guard infantry unit as part of Operation Enduring Freedom. Sung has also participated in several domestic operations, including those arising with respect to Hurricanes Sandy and Irma.
- Advised a major European online travel company (OTC) in negotiating U.S. tax aspects of a strategic alliance with a major American OTC
- Represented a leading provider of clinical software solutions in its acquisition by a private equity investment firm, in a transaction valued at $195 million
- Represented a client in the creation of a privately held REIT for two institutional investors to acquire an office property in Manhattan
- Represented a UK-based hedge fund in its relocation to the Cayman Islands
- Represented a Hong Kong-based asset management company in an investment in a joint venture to develop commercial real estate in the U.S.
- Represented a New York–based investment manager in a joint venture with an Argentine investment advisor, in establishing a private investment fund for investing in Argentine public equities, debt, private equity, and real estate
- Represented a Securities and Exchange Commission–registered investment adviser in restructuring its Cayman Islands master-feeder fund complex to reflect the addition of new share classes and changes to fee terms
- Represented an investment manager in the formation of a hedge fund that acted as both a fund-of-hedge funds and a direct investor
- Represented an international private investment bank regarding tax structuring, regulatory compliance, and risk mitigation issues for its outsourcing and employee sharing arrangements related to registering a U.S. broker-dealer subsidiary
- Represented a hedge fund in its sale to a publicly held special-purpose acquisition company organized in the Cayman Islands.
- LL.M. New York University School of Law 2002
- J.D. New York University School of Law 2000
- B.A. summa cum laude City University of New York, Hunter College 1995
Bar Admissions : New York
Court Admissions : U.S. Tax Court
Professional Memberships :
- Co-chair, Asian Practice Committee, New York County Lawyers Association
- Co-chair, Military & Veterans Committee, Asian American Bar Association of New York
- Member, American Legion
- Member, International Fiscal Association, U.S. Branch
- Member, Korean American Lawyers Association of Greater New York
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