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Ryan has broad experience advising multinational businesses, the asset management industry, and the real estate industry on the flexibility of partnership taxation. Through his work with venture capital and private equity funds, he has also developed an extensive knowledge as to the qualification of small business stock under Section 1202 of the Code which allows relevant investors the possibility of a multimillion-dollar tax exclusion upon an investment’s sale. Ryan received both his J.D. and M.S. in Taxation from Northeastern University, and a B.S. in Accounting from Plymouth State University. Ryan is a member of the Massachusetts Bar and licensed as a Certified Public Accountant in Washington, D.C. Ryan is also the primary author of Bloomberg BNA’s Portfolio 716 (dealing with the taxation of partnership current and liquidating distributions).
Andrew is a partner in the Passthrough Transactions Group of Ernst & Young
LLP’s National Tax Department, located in New York, with over 12 years of
public accounting experience.
Andrew specializes in partnership taxation, focusing on the use of
partnerships and limited liability companies in domestic and cross-border joint
ventures, mergers and acquisitions, financing transactions, dispositions, and
restructurings.
Andrew advises clients on fund structuring and transaction work. Andrew has
worked extensively with complicated joint venture structures in accounting for
various partnership matters including, capital account maintenance and
related income allocations, Section 734(b) and Section 743(b) adjustment
calculations, partnership liability allocations under Section 752, and disguised
sale calculations under Section 707.
Professional qualifications
Andrew has a B.A. from Queens College and an M.S. in Taxation from the
Zicklin School of Business at Baruch College.
Andrew is a Certified Public Accountant licensed in the State of New York
and a member of the American Institute of Certified Public Accountants
(AICPA). He is a member of the AICPA’s Partnership Taxation Technical
Resource Panel.
Speakers: Ryan Dobens, CPA, M.S., J.D. Senior Manager, Ernst & Young, LLP and Andrew Cohn, CPA, Partner, Ernst & Young, LLP
This session will identify, review, and consider related party basis shifting transactions as described by IRS Notice 2024-54, REG-124593-23, and Rev. Rul. 2024-14. The impact of this guidance, if finalized in its current form, would drastically implicate many common partnership transactions. This session will also discuss the AICPA’s comment letter on the related party basis shifting transaction guidance and cover new partnership distribution disclosures on IRS Form 7217.
Stephen Weinstein Senior Associate Washington, D.C.
Biography
Stephen Weinstein focuses his practice on mergers and acquisitions, domestic and cross-border transactions, joint ventures, tax credits, and other transactional tax matters.
Stephen regularly advises clients on complex real estate transactions and the renewable energy tax credits made available by the Inflation Reduction Act.
Prior to joining Hogan Love ls, Stephen was a tax associate in the Washington, D.C. office of another global law firm. Before that, Stephen was a manager at a leading accounting firm in their International Tax and Transaction Services group with a focus on U.S. federal income tax matters, mergers and acquisitions tax, and transaction structuring.
Representative experience
Fenway Sports Group and a consortium of team owners in a multi-bi lion do lar partnership with PGA TOUR to launch a new commercial venture that wi l operate the PGA’s golf assets. Equinor on its investment in two lithium project companies owned by Standard Lithium Ltd. C2X on its equity investment in and strategic partnership with Sungas Renewables. Latest thinking and events
LL.M., Georgetown University Law Center, Dean’s List with distinction, 2019
J.D., Touro Co lege Jacob D. Fuchsberg Law Center, Valedictorian, 2018
B.A. in Psychology, Fairfield University, 2013 Bar admissions and qualifications District of Columbia New York
Steven R. Schneider Partner Washington, D.C.
Biography
Steven is a nationally recognized tax lawyer who focuses his practice on transactional and tax policy matters primarily in the area of partnerships and limited liability companies. He has significant tax experience in mergers & acquisitions, private equity and real estate funds, energy transition, tax equity and credits, qualified opportunity zone funds, cross-border tax, partnerships, real estate, REITs, bioscience, international investors (including sovereigns), and S corporations.
He started his career as a lawyer in the U.S. Internal Revenue Service's national office and has had many years of national-level law firm and Big 4 accounting firm experience. Steven also previously chaired the ABA Partnership Tax Committee. He has been teaching a course on drafting partnership and LLC agreements at Georgetown University Law Center since 2005, is a regular speaker at national tax venues, and has published numerous articles.
Representative experience
Large global real estate funds, developers, and institutional investors on federal income tax matters relating to international and domestic real estate acquisitions, dispositions and restructurings.
* Frequent representation of sovereigns and other taxsensitive investors on real estate and fund investments.*
Regularly represents private equity funds on tax structuring, diligence, and documentation.*
Significant representations of multi-national corporations on strategic acquisitions, dispositions, and joint ventures.*
Successful representation of clients on significant federal tax controversy matters, including IRS audits and appeals.*
Clients and trade associations on tax legislative matters, primarily relating to real estate and pass-through entity taxation.*
Representations involving tax equity transactions in the renewables sector.*
Represent buyers and sellers in wind and solar project purchase and sale transactions.*
Representations involving Section 45X advanced manufacturing credit, Section 6426 and 40Z fuels credits, and Section 45 and 48 renewable energy credits.*
Education and admissions Education
L.L.M. in Law, Georgetown University Law Center, with Distinction, 1998
J.D., Order of the Coif, Washington University School of Law, 1994
B.S., University of Missouri, summa cum laude, 1991
Memberships American Bar Association - Tax Section, Partnerships and LLCs (Former Chair) Bar admissions and qualifications District of Columbia Court admissions U.S. Tax Court
Speakers: Steven Schneider, LL.M., J.D., Partner, Hogan Lovells US, LLP and Stephen Weinstein, Senior Associate, Hogan Lovells US, LLP
Ryan McCormick
Senior Vice President & Counsel
The Real Estate Roundtable, Tax Policy
Ryan McCormick is Senior Vice President and Counsel at The Real Estate Roundtable, where he is responsible for managing the organization’s tax policy activities. The Real Estate Roundtable brings together leaders of the nation’s top publicly held and privately owned real estate ownership, development, lending and management firms and leaders of major national real estate trade associations to jointly address key national policy issues relating to real estate and the overall economy. The Roundtable (www.rer.org) is located in Washington, D.C.
Ryan coordinates the activities of the Real Estate Roundtable’s Tax Policy Advisory Committee, a group of 150 leading real estate tax experts, including the in-house tax directors, general counsel, and chief financial officers of Roundtable members and senior partners from the country’s preeminent real estate advisory firms. The Roundtable’s Tax Policy Advisory Committee works to help lawmakers and federal officials understand how tax rules affect real estate activity, and it promotes pro-growth tax reforms that will facilitate sound, environmentally responsible real estate investment and development.
Ryan joined the Roundtable in May 2013 after serving nearly 11 years in the U.S. Senate as a tax and economic policy advisor for Senators Bob Graham, Pat Moynihan, John Kerry, Joe Lieberman, and Bill Nelson. In the Senate, he developed policy initiatives, drafted tax legislation, and devised legislative strategies to advance his Members’ economic priorities. In the 112th Congress, Ryan was Staff Director of the Senate Finance Subcommittee on Fiscal Responsibility and Economic Growth. As staff director, Ryan guided and oversaw all aspects of the subcommittee’s activities, including bipartisan hearings on tax reform and tax policy matters.
In addition to his service in the Senate, from 2006 until 2008, Ryan practiced tax law as an associate at Miller & Chevalier (“shev-a-leer”) in Washington, D.C., the oldest tax law firm in the country. He is a graduate of Georgetown University; Sciences-Po (“see-ons pō”) in Paris, France; and the University of Texas School of Law, where he was editor-in-chief of the Texas International Law Journal and received the Vinson & Elkins Presidential Scholarship in International Law. From 2000 to 2001, Ryan researched tax reform in West Africa as a Fulbright Scholar.
Speaker: Ryan McCormick, J.D., Senior Vice President & Counsel, Real Estate Roundtable
This session will identify, review, and consider key real estate tax issues likely to arise in the new Congress and Administration. What are the major tax policy challenges and opportunities for U.S. real estate and the real estate industry? How will the recent election influence tax legislation going forward? More specifically, what changes in tax policy could occur over the next two years, and how will those reforms affect U.S. real estate? Topics we will discuss include capital gains and gains-related proposals, such as: increasing the capital gains rate, taxing unrealized gains, ending the deferral of gain through like-kind exchanges, ending step-up in basis and taxing gains at death, changing the capital gains treatment of carried interest, and reforming the treatment of foreign investors' real estate gains. Other topics will include potential reforms of partnership and pass-through tax rules, the future of sections 199A, the net investment income tax, and bonus depreciation. The session will also consider the outlook for important housing (LIHTC), community development (Opportunity Zones), and clean energy incentives, in addition to new and novel proposals such as a federal tax credit for commercial-to-residential property conversions.
Megan A. Stoner, Esq.
Megan A. Stoner, J.D., LL.M., is a distinguished tax professional with
extensive expertise in partnership taxation, cultivated during her
tenure at BDO USA, PricewaterhouseCoopers LLP, and the IRS Office of
Chief Counsel (Passthroughs & Special Industries). Megan focuses in
providing strategic counsel on complex partnership transactions and
compliance issues. Her specialty includes advising partnerships
through restructuring transactions, mergers and business combinations,
and partnership debt-to-equity conversions and workouts. Megan
obtained her Master of Laws in Taxation from Georgetown University, a
Juris Doctor from the State University of New York at Buffalo Law
School, and a Bachelor of Arts in Philosophy from the University of
Rochester.
Speaker: Megan A. Stoner, Esq.
Paul Wilner
Professional Activities
Consultant Grossberg Company LLP
Retired, was past Managing Partner/ Head of Tax Practice
Technical Quality Control, Real Estate and Estate and Gift Taxation
Business and Transactional Consulting
IRS Tax Controversy Matters
Professional Organizations
Served as/on:
Tax Executive Committee, American Institute of Certified Public Accountants (AICPA)
Member AICPA Tax Executive Committee: Technical Reviewer - Partnership, S Corp., and Individual Tax Committees
Chair NYU annual National Real Estate and Partnership Tax Conferences
Chair AICPA’s National Partnership Technical Resource Panel (partnership taxation committee)
Chair AICPA’s annual National Real Estate Tax Conferences
Chair AICPA Task Force on Debt Reduction Basis Adjustments
Chair of Greater Washington Society of CPA’s Federal Taxation Committee
Member of AICPA (American Institute of Certified Public Accountants)
Member of AICPA’s Federal Tax Division
Chair of AICPA’s Task Force on Partnership Debt Allocations
Member of AICPA Tax Shelter Regulation Task Force
Member of Executive Committee, Jeffrey Henry International; Region of the Americas
Professional Development
Expert Witness Testimony before Treasury
Expert Witness for criminal and civil taxation matters
Author
Relief for Real Estate Professionals From Passive Activity Loss Rules,
TAX IDEAS, Warren, Gorham & Lamont
Disguised Sale Rules, §707(A), Taxation for Accountants, WG&L
Associated Accounting Firms International Booklet on Tax Aspects of Domestic Relations
Jeffreys Henry International Tax Planning Opportunities Guide
Associated Accounting Firms International, Year End Tax Planning Strategies
Lecturer/Instructor
The College of William and Mary, School of Law
NYU Real Estate and Partnership Tax Conferences
D.C. Bar / GWSCPA Pass-through Taxation Division
GWSCPA on Taxation of Real Estate
D.C. Bar Residential Property Committee
Kentucky Institute of Taxation
AICPA National Conference on Taxation and National Real Estate Tax Conference
MICPEL Annual Tax Seminar
Guest Instructor / Lecturer numerous other seminars on Taxation and Business
Listed in Washingtonian Magazine as one of the Top Tax Accountants in Washington D.C.
Career Experience
Comprehensive Tax Planning for High Net Worth Individuals and Family Groups
Specialization in Partnership Taxation and all phases of Real Estate Industry and related fields
Estate, Gift and Trust Taxation
Real Estate Transactional Tax and Business Consulting
Business and Real Property Acquisition Due Diligence Analysis
Speaker: Paul H. Wilner, CPA, Advisor, Grossberg Company
The grouping, and the definition, of activities can be different under different sections of the law. These differences can result in material variances in the tax treatment of the same items of income and deduction, causing complexity and confusion in proper reporting. For example, aggregation of separate activities and/or flow through entities under the at-risk rules may be applied under different rules than passive activity grouping or the grouping of activities under Section 1411 tax (“NIIT”). Further, the aggregation rules under Section 199A are different than those under Section 465 but are similar to those under Section 469 (with certain exceptions). The differences in how these rules are applied create complexities and material tax differences when reporting on tax returns. This session discusses the issues under these varying grouping rules.
Norm Lencz is a tax attorney who focuses his practice on matters relating to international, federal, state, and local tax. Norm advises clients on issues associated with corporations, partnerships, limited liability companies, joint ventures, real estate investment trusts (REITs), and regulated investment companies (RICs); tax-free and taxable mergers, acquisitions, and spin-offs; compensation planning; installment sales and like-kind exchanges; and real estate development and investment. His counsel covers all aspects of tax planning and tax controversy, leveraging his deep knowledge base and broad experience to provide creative solutions to any tax issues his clients confront.
Insights Thought Leadership 3 Key Improvements to Maryland Pass-Through Entity Tax March 26, 2021 March 2021 Update: SALT Deduction Workaround for Maryland Pass-Throughs Expanded and Improved March 16, 2021 Issues and Limitations with the Maryland SALT Deduction Workaround September 22, 2020
Christopher S. Davidson
Partner
Chris Davidson advises clients on a wide range of federal and state tax issues involving corporate, partnership, international, and individual income tax. Chris focuses primarily on foreign and domestic tax matters for partnerships, limited liability companies, and corporations. He frequently provides tax planning advice to wealthy individuals and entrepreneurs.
Maryland
Christopher N. Moran
Counsel
Chris Moran is a tax and nonprofit attorney who focuses primarily on nonprofit law, tax planning, and tax controversy. Chris assists clients with planning significant charitable gifts and setting up new charitable entities. He also has extensive experience with state and local tax compliance, federal and state income tax planning, and tax controversies.
In his work with nonprofit organizations, Chris has advised clients on the standards for managing endowments and complying with gift restrictions, and the corporate and tax consequences of joint ventures, mergers, and restructurings. Chris also has experience in counseling U.S. charities on tax and financial issues related to their activities in foreign countries.
Chris participates in a variety pro bono matters, particularly with low-income taxpayers and incarcerated persons. He earned his J.D. from Washington University School of Law in 2015, and received a BA, cum laude, from Wheaton College, where he also played varsity baseball.
Education
Bar Admissions
Court Admissions
Speaker: Norman Lencz, Esq., Partner, Venable, LLP, Christopher Davidson, LL.M., J.D., Partner, Venable, LLP, Christopher Moran, J.D., Counsel, Venable, LLP
Sales of partnership interest often involve complex tax issues, and this presentation will provide an overview of these tax issues, as well as planning ideas for the tax-efficient structuring of partnership interest sales. The implications of the recent case of Rawat v. Commissioner will also be discussed.