Sullivan
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Biography

  • Represented a REIT with structuring, in a tax-efficient and REIT-compliant manner, the liquidation of three subsidiary REITs, the divestment of property held by each subsidiary REIT, and return of capital to the parent entity
  • Represented a hotel and net-lease REIT as issuer’s counsel in connection with a $575 million underwritten public offering of common shares
  • Represented a healthcare REIT in a private offering of $375 million aggregate principal amount of senior secured notes
  • Provided REIT Tax counsel to a data center REIT in connection with three debt offerings totaling nearly $4 billion in aggregate principal amount
  • Designed tax structure for well over 2,000 M&A deals
  • Converted C corporations to public REITs in the travel centers, communication towers, business storage and data center industries
  • Designed tax structure for first REIT-to-REIT spin-off
  • Negotiated novel M&A structures including leveraged partnerships and master prepaid leases
  • Implemented efficient tax structures for REITs investing in 50 countries throughout Europe, Asia and Latin America
  • Defended the portfolio interest exemption from IRS challenge to an Islamic law-compliant transaction denominated as a lease rather than a loan

Matters

  • Represented a REIT with structuring, in a tax-efficient and REIT-compliant manner, the liquidation of three subsidiary REITs, the divestment of property held by each subsidiary REIT, and return of capital to the parent entity
  • Represented a hotel and net-lease REIT as issuer’s counsel in connection with a $575 million underwritten public offering of common shares
  • Represented a healthcare REIT in a private offering of $375 million aggregate principal amount of senior secured notes
  • Provided REIT Tax counsel to a data center REIT in connection with three debt offerings totaling nearly $4 billion in aggregate principal amount
  • Designed tax structure for well over 2,000 M&A deals
  • Converted C corporations to public REITs in the travel centers, communication towers, business storage and data center industries
  • Designed tax structure for first REIT-to-REIT spin-off
  • Negotiated novel M&A structures including leveraged partnerships and master prepaid leases
  • Implemented efficient tax structures for REITs investing in 50 countries throughout Europe, Asia and Latin America
  • Defended the portfolio interest exemption from IRS challenge to an Islamic law-compliant transaction denominated as a lease rather than a loan

Matters

Matters

Matters

  • Represented a REIT with structuring, in a tax-efficient and REIT-compliant manner, the liquidation of three subsidiary REITs, the divestment of property held by each subsidiary REIT, and return of capital to the parent entity
  • Represented a hotel and net-lease REIT as issuer’s counsel in connection with a $575 million underwritten public offering of common shares
  • Represented a healthcare REIT in a private offering of $375 million aggregate principal amount of senior secured notes
  • Provided REIT Tax counsel to a data center REIT in connection with three debt offerings totaling nearly $4 billion in aggregate principal amount
  • Designed tax structure for well over 2,000 M&A deals
  • Converted C corporations to public REITs in the travel centers, communication towers, business storage and data center industries
  • Designed tax structure for first REIT-to-REIT spin-off
  • Negotiated novel M&A structures including leveraged partnerships and master prepaid leases
  • Implemented efficient tax structures for REITs investing in 50 countries throughout Europe, Asia and Latin America
  • Defended the portfolio interest exemption from IRS challenge to an Islamic law-compliant transaction denominated as a lease rather than a loan

Matters

One of the Largest Global REITs and Its Subsidiary Form a New Joint Venture

Our marquee REIT and Tax teams advised American Tower Corporation (NYSE: AMT), one of the largest global REITs, and its subsidiary CoreSite in the formation of a new joint venture with Stonepeak, a leading alternative investment firm specializing in infrastructure and real property assets, to develop, build and operate an 18-megawatt data center in Denver, Colorado. CoreSite provides IT infrastructure that empowers enterprises and cloud, network and IT service providers to monetize and future-proof their digital businesses. The total estimated development costs for the 18-megawatt data center are expected to be more than $250 million.

Sullivan’s team was led by Ameek Ashok Ponda, director of the Tax Department, with Sullivan Tax partners Joel Carpenter and Sarah Wellings, and associate Connie Lee, contributing to the successful deal.

Ameek Ashok Ponda, Joel R. Carpenter, Sarah D. Wellings and Connie Lee

Matters