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Portrait of Sarah D. Wellings
Portrait of Sarah D. Wellings

Biography

Sarah is co-leader of Sullivan’s REITs Practice Group. She advises public and private REITs, both domestic and foreign, in various industries, including data centers, office buildings, commercial retail space, hospitality, multi-family residential, senior living facilities, cold storage facilities, industrial properties, communications towers, distributed antenna systems, timberlands and agricultural properties. She focuses on structuring and compliance work, including cross-border transactions.

In addition, Sarah advises clients in state and local tax transactional planning and litigation involving corporate, franchise, and sales/use tax matters. Sarah also has experience in advising tax-exempt organizations, including public charities, on all aspects of operations.

Sarah is an adjunct professor with the Villanova University Charles Widger School of Law Graduate Tax Program, where for over 12 years she has taught tax courses on state and local tax planning and state and local tax controversy.

Education
  • Boston University School of Law (LL.M., salutatorian)
    • Taxation
  • Boston College Law School (J.D., magna cum laude)
  • Shimer College (B.A., with great distinction)
Bar & Court Admissions
  • Massachusetts
Professional Qualifications
  • American Bar Association, Tax Section
  • Boston Bar Association
  • Adjunct Professor, Villanova University School of Law
Awards & Honors
  • Chambers USA, "Up & Coming" Lawyer in REITs: Tax (Nationwide) (2025-2026)
  • Best Lawyers in America® (2026-2027)
  • Recognized as a Next Generation Partner by The Legal 500 U.S. (2024-2026)
  • Recommended by The Legal 500 U.S. (2024-2026)
  • "Rising Star," Massachusetts Super Lawyers (2008-2010)
Client Highlights
All Client Highlights
Viewpoints
All Viewpoints
Remediation of M&A REIT Targets
Ameek Ashok Ponda, Sarah Wellings and Connie Lee updated their white paper, "Remediation of M&A REIT Targets," for additional administrative authorities, deal precedents, and recent case law. The white paper was published most recently by Practising Law Institute’s “Real Estate M&A and REIT Transactions” as part of its 2024 Real Estate Practice Course Handbook Series and serves as the playbook for diligencing and remediating real or perceived REIT qualification failures.
Impact of 21st Century ROAD to Housing Act on Institutional Investor Ownership of Single-Family Rental Homes
The U.S. Congress passed the 21st Century ROAD to Housing Act (the “Housing Act”) and presented it to President Trump on June 29, 2026. At midnight on July 10, 2026, the Housing Act became law because the President did not return it to Congress within ten days (Sundays excepted). The Housing Act includes a wide range of housing reforms designed with the goal of making housing more available and affordable.  This alert focuses on the impact of the Housing Act on institutional investor ownership of single-family rental homes.  The Housing Act does not prohibit institutional investor ownership of manufactured homes. The section of the Housing Act impacting institutional investor ownership of single-family rental homes is Section 1001 (the Section is titled “Homes Are for People, Not Corporations”).  The primary impacts under Section 1001 are (i) a prohibition on purchases of single-family homes (with important exceptions) and (ii) the creation of a “Renter Outreach Resource” managed by the federal government.  Section 1001 uses a number of defined terms, which are summarized in Appendix A to this alert.  The defined terms are indicated in this alert in italics.  The most important – and most extensive – defined term is excepted purchase, which includes, among other programs, purchases of single-family homes pursuant to build-to-rent programs and purchases of single-family homes from other large institutional investors. No Requirement to Dispose When the U.S. Senate passed a version of the Housing Act in March 2026, the legislation included a controversial, perhaps even unconstitutional, provision requiring institutional investors to dispose of certain single-family homes not later than seven years after the date of purchase.  A relief to such institutional investors, the Housing Act, as enacted, does not include that requirement to dispose. Prohibition on Purchases (with Several Exceptions) The Housing Act prohibits the purchase of single-family homes by large institutional investors, excluding any excepted purchase or any purchase of a single-family home in connection with a restructuring or other reorganization of ownership of single-family homes that were owned or purchased on or before the date of enactment of the Housing Act.  The prohibition on purchases takes effect on January 7, 2027 (180 days after the date of enactment of the Housing Act) (the “Effective Date”) and is repealed on January 7, 2042 (15 years after the Effective Date). Excepted purchases (i.e., those not prohibited) are described in detail in Appendix A under the defined term “Excepted Purchase”, but generally include many of the common methods by which institutional investors in single-family rental homes acquire such homes, including but not limited to: (i) build‑to‑rent programs, (ii) renovate‑to‑rent programs, (iii) repossessions, (iv) foreclosures, (v) purchases from another large institutional investor, or (vi) combinations of (i) through (v). Enforcement of Prohibition on Purchases The Secretary of the Treasury, or the Attorney General at the request of the Secretary of the Treasury, may bring an action against a large institutional investor that violates the prohibition on purchases for a civil penalty in an amount that is not more than $1,000,000 per violation, or three times the purchase price of the property involved, whichever is greater. Renter Outreach Resource As described in detail below, the Renter Outreach Resource is a comprehensive program that includes direct reporting of rental disputes by renters to Federal agencies, with investigation and reporting requirements imposed on applicable Federal agencies, and (at a minimum) provision of applicable state agency contact information to renters to facilitate state-level investigation.  In addition, large institutional investors must respond to information requests in connection with any investigation and are required to regularly provide certain information regarding the Renter Outreach Resource to their renters. Establishment of Renter Outreach Resource The Secretary of Housing and Urban Development (the “HUD Secretary”) is required, not later than 180 days after the date of enactment of the Housing Act, to establish the Renter Outreach Resource that consists of a toll-free telephone number and a public website designed to assist renters of residential properties owned by a large institutional investor in –  notifying Federal agencies about disputes relating to the rental of such properties, including disputes about potential violations of Federal law; sharing information about such disputes with other Federal agencies, including other Federal agencies that manage similar disputes; monitoring such disputes; and resolving such disputes, to the extent practicable.   Response to Outreach The HUD Secretary is required to establish reasonable procedures to promptly respond, in writing where appropriate, to a renter who provides information to the HUD Secretary about a dispute using the Renter Outreach Resource and document such responses.  Such responses are required to include, where appropriate, information about –  steps that have been taken by the HUD Secretary or another Federal agency in response to the information about the dispute provided by the renter, including determining the appropriate large institutional investor involved as described in the bullet below “Investigation of Potential Violations of Federal Law;” any responses received by the HUD Secretary or another Federal agency from the large institutional investor related to such dispute; and any outcome of the dispute, to the extent practicable.   Investigation of Potential Violations of Federal Law The HUD Secretary is required to promptly process and investigate any information relating to a dispute received through the Renter Outreach Resource about a potential violation of Federal law that is received from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, including –  requesting information from a large institutional investor; determining the appropriate large institutional investor involved in the dispute; and sharing information about such potential violation of Federal law with any relevant Federal agencies, as the HUD Secretary may determine appropriate.   Upon request for information made pursuant to the Renter Outreach Resource, the HUD Secretary is required to provide a large institutional investor the opportunity to respond, including regarding whether such large institutional investor currently owns the property described in such request for information.   Information for Appropriate State Authority When the HUD Secretary receives information about a potential violation of State law or about a dispute received through the Renter Outreach Resource, from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, the HUD Secretary is required, at a minimum, to provide the renter with contact information for the appropriate, State-specific, State authority authorized to process and investigate such information.   Notice About Renter Outreach Resource Each large institutional investor is required to –  provide to each renter of a residential property owned by such investor at the time such renter first occupies such home and annually thereafter –  written notice about the Renter Outreach Resource; and the name, phone number, and email address of the person or entity responsible for receiving and addressing renter disputes for the large institutional investor, and update the name, phone number, and email address within 30 days if such information changes prior to the subsequent time at which such notice is required to be provided; and   prominently feature information about the Renter Outreach Resource on a public website of such investor that is accessible by such renter.   Annual Notification Not later than 180 days after the date of enactment of the Housing Act, and not later than December 31st of each year thereafter, each person or entity that satisfies the definition of a large institutional investor is required to –  notify the HUD Secretary each year whether such owner is a large institutional investor; and in such notification, identify how many single-family homes such large institutional investor has direct or indirect investment control of as of the date of the submission of such notice, and the city and State where each such single-family home is located, unless such large institutional investor owns ten or fewer single-family homes in such city. Studies on Large Institutional Investors Not later than two years after the Effective Date, and again not later than ten years after the Effective Date, a GAO report and a HUD report are required to be submitted to the House Banking Committee and the Senate Committee on Financial Services. *     *     * Contacts Tax Cameron N. Cosby Carson Durdel Connie Lee Ameek Ashok Ponda Sarah D. Wellings Private Funds William C. Hanson Real Estate Karen J. Kepler Louis A. Monti John M. Steiner Appendix A Defined Terms in Section 1001 of the Housing Act Consumer Reporting Agency:  The term “consumer reporting agency” has the meaning given the term in section 603 of the Fair Credit Reporting Act (15 U.S.C. 1681a)). Excepted Purchase:  The term “excepted purchase” means any purchase of a single-family home that is –  Newly Constructed, For Sale Home Newly constructed, renovated, or a rental conversion for sale by a large institutional investor and not as a residence rented pending sale;   Build-to-Rent Program Pursuant to a build-to-rent program where the large institutional investor purchases newly constructed single-family homes to be managed as rental properties, whether as communities exclusively of renter-occupied single-family homes or as communities of single-family homes that are both owner- and renter-occupied;   Renovate-to-Rent Program Pursuant to a renovate-to-rent program that –  substantially rehabilitates single-family homes that do not meet structural or core system elements of local building codes; and makes improvements in an aggregate dollar amount of not less than 15% of the purchase price of the single-family home;   Homeownership Program Pursuant to a homeownership program that –  requires rental payments and any other fees that are not greater than those collected by the large institutional investor on other similarly situated single-family homes not covered by the eligible homeownership program; is subject to a contract between the large institutional investor and renter that shall be considered a consumer credit transaction secured by a dwelling or real property; provides for positive reporting of rental payments to consumer reporting agencies for any renter, who shall be informed of and opts into such reporting; and requires contribution of meaningful financial support from the large institutional investor, including price concessions, for the purchase of the single-family home by the renter;   Program to Boost Homeownership Pursuant to a program to boost homeownership that –  provides for positive reporting of rental payments to consumer reporting agencies for any renter who is informed of and opts into such reporting; provides for the right of first refusal and a 30-day ‘‘first look’’ period; and may entail the meaningful financial support from the large institutional investor, including price concessions, for the purchase of a single-family home by the renter (whether it is the home the renter occupies or another home);   Repossession In connection with the satisfaction of debts previously contracted in good faith and where the large institutional investor has the right to repossess the single-family home under such contract;   Foreclosure Undertaken by a mortgage servicer, lender, or other entity that has a legal right to a single-family home, for the purpose of loss mitigation or compliance with servicing or investor obligations, and not as a long-term investment strategy, and is solely as a result of –  a foreclosure; a deed-in-lieu of foreclosure; enforcement of a mortgage, deed of trust, or other security interest; or operation of law following borrower default;   Purchase from Another Large Institutional Investor Purchased from another large institutional investor that either owned the single-family home on the date of enactment of the Housing Act or purchased the single-family home in compliance with Section 1001;   Purchase from Investor Not a Large Institutional Investor Purchased from an investor not covered under Section 1001, so long as the purchase occurred not more than two years after the Effective Date;   Newly Constructed Single-Family Home in Senior Community Newly constructed, renovated, or a rental conversion that is intended and operated for occupancy as part of a community for households with one or more members aged 55 years or older, and satisfies visitability standards established by the HUD Secretary; or   Combination of Foregoing Purchases Purchased through a single purchase or combination or series of purchases described in the foregoing bullet points.   Large Institutional Investor:  The term “large institutional investor” means an investment fund, corporation, general or limited partnership, limited liability company, joint venture, association, or other for-profit entity that is a legal entity structured in a manner that is not aforementioned that –  is engaged, in whole or in part, in the business of investing in, owning, renting, managing, or holding single-family homes; and alone or in concert with one or more other entities, beginning after the date of enactment of the Housing Act, directly or indirectly has investment control of not less than 350 single-family homes in the aggregate, not including any single-family home purchased in an excepted purchase made after the date of enactment of the Housing Act.   A large institutional investor does not include any local, State, Tribal, or Federal government entity or instrumentality thereof. For purposes of the definition of “large institutional investor”, an entity has direct or indirect investment control over a single-family home if the entity –  owns, or has primary authority or fiduciary responsibility to make material investment or management decisions relating to, the single-family home; is, or directly or indirectly controls, the general partner or managing member of the entity that owns the single-family home; is or controls the investment manager, management company, or investment advisor of the entity that owns the single-family home; owns or controls more than 25% of any class of equity interests of the entity that owns the single-family home, unless such entity is a passive investor; or otherwise controls the entity that owns the single-family home.   Purchase:  The term “purchase” includes any purchase, transfer, or other acquisition of a single-family home, including through mergers, acquisitions, construction, foreclosures, or bulk purchases, whether or not for cash consideration.   Single-Family Home:  The term “single-family home” means a structure that contains two or fewer dwelling units that are each intended for residential occupancy by a single household.  The term “single-family home” does not include a manufactured home, as defined in section 603 of the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5402).
News
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44 Sullivan & Worcester Lawyers Selected as “Best Lawyers” Award Recipients
Boston, MA – Sullivan & Worcester today announced that 44 lawyers were recognized in the 2027 edition of Best Lawyers in America®. 40 of the firm’s lawyers in Boston, New York and Washington, D.C. were selected as “Best Lawyers in America®,” and four Sullivan lawyers were recognized as “Ones to Watch” in the U.S. Best Lawyers in America® The firm’s 2027 Best Lawyers in Boston include Victor Baltera (Environmental Law, Real Estate Law); Howard Berkenblit (Corporate Governance Law, Corporate Law); Harvey Bines (Corporate Compliance Law, Corporate Governance Law, Corporate Law); Ashley Brooks (Real Estate Law); Joel Carpenter (Tax Law); Henry Comstock, Jr. (Trusts and Estates); Christopher Curtis (Tax Law); Patrick Dinardo (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation - Bankruptcy); John Graham (Nonprofit / Charities Law, Tax Law); David Guadagnoli (Employee Benefits (ERISA) Law, Tax Law); Warren Heilbronner (Real Estate Law); Zachary Hyde (Patent Law); Richard Jones (Tax Law); Karen Kepler (Real Estate Law); Caroline Kupiec (Tax Law); Thomas Meyers (Patent Law); Lisa Mingolla (Trusts and Estates); Louis Monti (Real Estate Law); Cornelius Murray III (Trusts and Estates); David Nagle (Litigation and Controversy - Tax, Tax Law); Ameek Ashok Ponda (Tax Law); Gregory Sampson (Environmental Law, Land Use and Zoning Law, Real Estate Law); Lewis Segall (Corporate Law, Mergers and Acquisitions Law); Amy Sheridan (Employee Benefits (ERISA) Law, Tax Law); Laura Steinberg (Commercial Litigation); John Steiner (Real Estate Law); Douglas Stransky (Tax Law); Sarah Wellings (Tax Law); and Amy Zuccarello (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation - Bankruptcy). Sullivan’s 2027 Best Lawyers in Washington, D.C. include John Chilton (Mutual Funds Law); Cameron Cosby (Tax Law); Nicole Crum (Mutual Funds Law); David Leahy (Mutual Funds Law); David Mahaffey (Mutual Funds Law, Securities Regulation); and Stephanie Monaco (Corporate Law, Mutual Funds Law, Private Funds / Hedge Funds Law, Securities Regulation). The firm’s 2027 Best Lawyers in New York include Carole Bass (Trusts and Estates); J. Truman Bidwell, Jr. (Corporate Law); Domenick Pugliese (Mutual Funds Law); Constantine Ralli (Trusts and Estates); and Marc Stern (Trusts and Estates). Best Lawyers: Ones to Watch Awardees Best Lawyers awards this recognition to attorneys who are earlier in their careers for their outstanding professional excellence in private practice in the United States. Sullivan’s lawyers earning this award include Alexander Gansebom (Corporate Governance and Compliance Law, Corporate Law, Health Care Law, Mergers and Acquisitions Law, Real Estate Law); Emily Goldschmidt (Corporate Law); Ryan Rosenblatt (Commercial Litigation); and Ashley Tan (Real Estate Law). Best Lawyers Selection Methodology Recognition by Best Lawyers in America® is based on a peer review process designed to capture the consensus opinion of leading lawyers about the professional abilities of their colleagues within the same geographical and legal practice areas. About Sullivan Sullivan & Worcester (Sullivan) is a premier, AmLaw 200 international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
Top Tier Firm, Legal 500 United States 2026
Sullivan & Worcester Ranked in the Legal 500 United States 2026 Edition
Boston, MA – Sullivan & Worcester announced that its practice groups and attorneys have been ranked and recommended in the Legal 500 United States 2026. The firm’s Real Estate practice was newly ranked Tier 1 in the “Real estate – mid-market ($0-500m)” category and the firm maintained rankings across a variety of practice areas. Partners Nicole Crum and John Steiner were newly ranked as Leading Partners and Ryan Rosenblatt as a Next Generation Partner. Peers and more than 300,000 corporate counsel were surveyed and interviewed globally in the past 12 months to assess law firms’ overall visibility and reputation, culminating in detailed rankings and editorial. The Legal 500 is an independent guide, and firms and individuals are recommended purely on merit. Sullivan's lawyers received the following rankings: Leading Partners: The Legal 500’s Guide to Outstanding Lawyers Nationwide Benjamin Armour - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) Ameek Ashok Ponda - Real Estate Investment Trusts (REITs)  Nicole Crum - Mutual/registered/exchange-traded funds Lewis Segall - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) John Steiner - Real estate – mid-market ($0-500m) Douglas Stransky - International Tax Joel Telpner - Fintech Next Generation Partners: The Legal 500’s Guide to Up-and-Coming Lawyers Nationwide Ryan Rosenblatt - General commercial disputes – mid-market ($250-500m) Sarah Wellings - Real Estate Investment Trusts (REITs) Practice Areas Ranked and Attorneys Recognized Corporate Governance “Our lead partner, Nicole Crum, who leads the investment industry practice, is exceptional. She demonstrates strong industry knowledge yet is very personable and anticipates what we need to know or what we should consider doing to handle any matter. The team roll up their sleeves and provide recommendations as to how we as a board should handle any matter. Strong service commitment and work ethic!” “The team we have at Sullivan & Worcester has served our company for years and knows the management team, staff as well as our board members. They are extremely responsive and proactive and anticipate what we should be aware of, concerned about, excited about, and how to handle oversight, processes and protocols to ensure we are carrying out our fiduciary duties. The partners are experts in this industry.” Leading Partner: Nicole Crum Recommended Lawyers: Howard Berkenblit, David Leahy Dispute Resolution/General Commercial Disputes “Diverse skillset. Client centric. Transparency. Urgency provided on all matters.” “I have worked with Gerry Silver for over 15 years and have found his pragmatic approach to complex matters refreshing. He understands our business, culture and market, and will give me his opinion in a digestible manner.” Next Generation Partner: Ryan Rosenblatt Recommended Lawyers: Gerry Silver, Patrick Dinardo, Laura Steinberg, Michael Sullivan, Amy Zuccarello, Erika Todd, Christopher Shields, Anna Lea McNerney Employee Benefits, Executive Compensation and Retirement Plans: Design “The level of expertise is top shelf. David Guadagnoli seems to know all of ERISA and IRS rulings.” “David Guadagnoli and Amy Sheridan both have superior knowledge in their respective areas. I value the ability to raise issues whether simple or complex. The firm takes the same diligent approach across all spectrums of complexity.” Recommended Lawyers: David Guadagnoli, Amy Sheridan Environment: Transactional Fintech “Sullivan & Worcester is one of the finest firms with which I have worked.” “The lawyers are excellent, and the firm consistently provides the highest quality of customer service.” Leading Partner: Joel Telpner Recommended Lawyers: Natalie Lederman, Benjamin Armour, Scott Kaufman, Harvey Bines, Christopher Curtis Land Use/Zoning Recommended Lawyers: Gregory Sampson, Ashley Brooks, Victor Baltera, Karen Kepler, Ashley Tan M&A: Corporate and Commercial: Venture Capital and Emerging Companies Recommended Lawyers: Scott Kaufman, Lewis Segall, Benjamin Armour, Michael Student M&A: Middle-Market ($0-250m) “The partner Lewis Segall has been working with our company for 15 years and we have a good working relationship with him. He knows our history and very attentive to our needs.” “Lewis Segall is very attentive to our needs. We very much value him.” Leading Partners: Benjamin Armour, Lewis Segall Recommended Lawyers: Natalie Lederman Mutual/Registered/Exchange-Traded Funds “Sullivan & Worcester's practice is defined by its deep expertise in investment funds and its ability to deliver clear, commercially grounded advice across the full fund lifecycle—from formation and structuring to regulatory compliance and complex transactions.” “The team is highly experienced, collaborative, and excel in efficient execution and clear communication.” Leading Partner: Nicole Crum Recommended Lawyers: David Leahy, David Mahaffey, Rachael Schwartz Real Estate Leading Partner: John Steiner Recommended Lawyers: Ashley Brooks, Karen Kepler, Gregory Sampson, Sharon Leifer, Louis Monti, Spencer Stone, Ashley Tan Real Estate Investment Trusts (REITs) “We have built multiple complex and sophisticated REIT platforms over the years and worked with many top-tier REIT specialists, but Sullivan’s REIT practice is by far the best, with Sarah Wellings.” Leading Partner: Ameek Ashok Ponda Next Generation Partner: Sarah Wellings Recommended Lawyers: Angela Gomes, Louis Monti, Shu Wei, Cameron Cosby International Tax “The international collaboration with S&W is exceptional.” “What really stands out is their willingness to engage, openness to different ideas and opinions, clearly expressed expectations, and clients' objectives.” Leading Partner: Douglas Stransky Recommended Lawyers: Lewis Greenwald, Eric Rietveld Tax > US Taxes: Contentious Recommended Lawyers: Richard Jones, David Nagle, Daniel Ryan, Caroline Kupiec Tax > US Taxes: Non-Contentious “Sarah Wellings is, quite simply, the best lawyer we have ever worked with. Her expertise extends far beyond tax and REIT matters, encompassing governance, financing, and complex commercial issues. Decades of experience and technical mastery make her an indispensable partner. Sarah is our central point of contact who makes everything seamless. Her in-house counsel background gives her a unique client perspective: she anticipates needs, solves problems before they arise, and delivers concise, well-structured updates that simplify even the most intricate issues. She coordinates effortlessly with all parties involved. Her judgment is exceptional. Sarah strikes the perfect balance between comprehensive academic rigor and practical, business-oriented advice. She combines technical REIT/tax excellence with commercial instincts, ensuring every recommendation is both legally sound and strategically smart. Her ability to translate complex law into clear, actionable guidance is unmatched. Sarah is incredibly responsive without ever sacrificing quality. She treats our matters as her own, demonstrating a rare ownership mindset and collaborative spirit. Her integrity is uncompromising, giving us absolute confidence in her counsel. In short, Sarah Wellings defines legal excellence: reliable, commercially minded, and client-focused. Working with her feels like being in the safest possible hands; she consistently exceeds expectations and orchestrates complex transactions with clarity and precision.” Recommended Lawyers: Ameek Ashok Ponda, Richard Jones, Douglas Stransky, Sarah Wellings About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.

Sarah D. Wellings

Sarah is co-leader of Sullivan’s REITs Practice Group. She advises public and private REITs, both domestic and foreign, in various industries, including data centers, office buildings, commercial retail space, hospitality, multi-family residential, senior living facilities, cold storage facilities, industrial properties, communications towers, distributed antenna systems, timberlands and agricultural properties. She focuses on structuring and compliance work, including cross-border transactions.

In addition, Sarah advises clients in state and local tax transactional planning and litigation involving corporate, franchise, and sales/use tax matters. Sarah also has experience in advising tax-exempt organizations, including public charities, on all aspects of operations.

Sarah is an adjunct professor with the Villanova University Charles Widger School of Law Graduate Tax Program, where for over 12 years she has taught tax courses on state and local tax planning and state and local tax controversy.

Client Highlights
All Client Highlights
Viewpoints
All Viewpoints
Remediation of M&A REIT Targets
Ameek Ashok Ponda, Sarah Wellings and Connie Lee updated their white paper, "Remediation of M&A REIT Targets," for additional administrative authorities, deal precedents, and recent case law. The white paper was published most recently by Practising Law Institute’s “Real Estate M&A and REIT Transactions” as part of its 2024 Real Estate Practice Course Handbook Series and serves as the playbook for diligencing and remediating real or perceived REIT qualification failures.
Impact of 21st Century ROAD to Housing Act on Institutional Investor Ownership of Single-Family Rental Homes
The U.S. Congress passed the 21st Century ROAD to Housing Act (the “Housing Act”) and presented it to President Trump on June 29, 2026. At midnight on July 10, 2026, the Housing Act became law because the President did not return it to Congress within ten days (Sundays excepted). The Housing Act includes a wide range of housing reforms designed with the goal of making housing more available and affordable.  This alert focuses on the impact of the Housing Act on institutional investor ownership of single-family rental homes.  The Housing Act does not prohibit institutional investor ownership of manufactured homes. The section of the Housing Act impacting institutional investor ownership of single-family rental homes is Section 1001 (the Section is titled “Homes Are for People, Not Corporations”).  The primary impacts under Section 1001 are (i) a prohibition on purchases of single-family homes (with important exceptions) and (ii) the creation of a “Renter Outreach Resource” managed by the federal government.  Section 1001 uses a number of defined terms, which are summarized in Appendix A to this alert.  The defined terms are indicated in this alert in italics.  The most important – and most extensive – defined term is excepted purchase, which includes, among other programs, purchases of single-family homes pursuant to build-to-rent programs and purchases of single-family homes from other large institutional investors. No Requirement to Dispose When the U.S. Senate passed a version of the Housing Act in March 2026, the legislation included a controversial, perhaps even unconstitutional, provision requiring institutional investors to dispose of certain single-family homes not later than seven years after the date of purchase.  A relief to such institutional investors, the Housing Act, as enacted, does not include that requirement to dispose. Prohibition on Purchases (with Several Exceptions) The Housing Act prohibits the purchase of single-family homes by large institutional investors, excluding any excepted purchase or any purchase of a single-family home in connection with a restructuring or other reorganization of ownership of single-family homes that were owned or purchased on or before the date of enactment of the Housing Act.  The prohibition on purchases takes effect on January 7, 2027 (180 days after the date of enactment of the Housing Act) (the “Effective Date”) and is repealed on January 7, 2042 (15 years after the Effective Date). Excepted purchases (i.e., those not prohibited) are described in detail in Appendix A under the defined term “Excepted Purchase”, but generally include many of the common methods by which institutional investors in single-family rental homes acquire such homes, including but not limited to: (i) build‑to‑rent programs, (ii) renovate‑to‑rent programs, (iii) repossessions, (iv) foreclosures, (v) purchases from another large institutional investor, or (vi) combinations of (i) through (v). Enforcement of Prohibition on Purchases The Secretary of the Treasury, or the Attorney General at the request of the Secretary of the Treasury, may bring an action against a large institutional investor that violates the prohibition on purchases for a civil penalty in an amount that is not more than $1,000,000 per violation, or three times the purchase price of the property involved, whichever is greater. Renter Outreach Resource As described in detail below, the Renter Outreach Resource is a comprehensive program that includes direct reporting of rental disputes by renters to Federal agencies, with investigation and reporting requirements imposed on applicable Federal agencies, and (at a minimum) provision of applicable state agency contact information to renters to facilitate state-level investigation.  In addition, large institutional investors must respond to information requests in connection with any investigation and are required to regularly provide certain information regarding the Renter Outreach Resource to their renters. Establishment of Renter Outreach Resource The Secretary of Housing and Urban Development (the “HUD Secretary”) is required, not later than 180 days after the date of enactment of the Housing Act, to establish the Renter Outreach Resource that consists of a toll-free telephone number and a public website designed to assist renters of residential properties owned by a large institutional investor in –  notifying Federal agencies about disputes relating to the rental of such properties, including disputes about potential violations of Federal law; sharing information about such disputes with other Federal agencies, including other Federal agencies that manage similar disputes; monitoring such disputes; and resolving such disputes, to the extent practicable.   Response to Outreach The HUD Secretary is required to establish reasonable procedures to promptly respond, in writing where appropriate, to a renter who provides information to the HUD Secretary about a dispute using the Renter Outreach Resource and document such responses.  Such responses are required to include, where appropriate, information about –  steps that have been taken by the HUD Secretary or another Federal agency in response to the information about the dispute provided by the renter, including determining the appropriate large institutional investor involved as described in the bullet below “Investigation of Potential Violations of Federal Law;” any responses received by the HUD Secretary or another Federal agency from the large institutional investor related to such dispute; and any outcome of the dispute, to the extent practicable.   Investigation of Potential Violations of Federal Law The HUD Secretary is required to promptly process and investigate any information relating to a dispute received through the Renter Outreach Resource about a potential violation of Federal law that is received from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, including –  requesting information from a large institutional investor; determining the appropriate large institutional investor involved in the dispute; and sharing information about such potential violation of Federal law with any relevant Federal agencies, as the HUD Secretary may determine appropriate.   Upon request for information made pursuant to the Renter Outreach Resource, the HUD Secretary is required to provide a large institutional investor the opportunity to respond, including regarding whether such large institutional investor currently owns the property described in such request for information.   Information for Appropriate State Authority When the HUD Secretary receives information about a potential violation of State law or about a dispute received through the Renter Outreach Resource, from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, the HUD Secretary is required, at a minimum, to provide the renter with contact information for the appropriate, State-specific, State authority authorized to process and investigate such information.   Notice About Renter Outreach Resource Each large institutional investor is required to –  provide to each renter of a residential property owned by such investor at the time such renter first occupies such home and annually thereafter –  written notice about the Renter Outreach Resource; and the name, phone number, and email address of the person or entity responsible for receiving and addressing renter disputes for the large institutional investor, and update the name, phone number, and email address within 30 days if such information changes prior to the subsequent time at which such notice is required to be provided; and   prominently feature information about the Renter Outreach Resource on a public website of such investor that is accessible by such renter.   Annual Notification Not later than 180 days after the date of enactment of the Housing Act, and not later than December 31st of each year thereafter, each person or entity that satisfies the definition of a large institutional investor is required to –  notify the HUD Secretary each year whether such owner is a large institutional investor; and in such notification, identify how many single-family homes such large institutional investor has direct or indirect investment control of as of the date of the submission of such notice, and the city and State where each such single-family home is located, unless such large institutional investor owns ten or fewer single-family homes in such city. Studies on Large Institutional Investors Not later than two years after the Effective Date, and again not later than ten years after the Effective Date, a GAO report and a HUD report are required to be submitted to the House Banking Committee and the Senate Committee on Financial Services. *     *     * Contacts Tax Cameron N. Cosby Carson Durdel Connie Lee Ameek Ashok Ponda Sarah D. Wellings Private Funds William C. Hanson Real Estate Karen J. Kepler Louis A. Monti John M. Steiner Appendix A Defined Terms in Section 1001 of the Housing Act Consumer Reporting Agency:  The term “consumer reporting agency” has the meaning given the term in section 603 of the Fair Credit Reporting Act (15 U.S.C. 1681a)). Excepted Purchase:  The term “excepted purchase” means any purchase of a single-family home that is –  Newly Constructed, For Sale Home Newly constructed, renovated, or a rental conversion for sale by a large institutional investor and not as a residence rented pending sale;   Build-to-Rent Program Pursuant to a build-to-rent program where the large institutional investor purchases newly constructed single-family homes to be managed as rental properties, whether as communities exclusively of renter-occupied single-family homes or as communities of single-family homes that are both owner- and renter-occupied;   Renovate-to-Rent Program Pursuant to a renovate-to-rent program that –  substantially rehabilitates single-family homes that do not meet structural or core system elements of local building codes; and makes improvements in an aggregate dollar amount of not less than 15% of the purchase price of the single-family home;   Homeownership Program Pursuant to a homeownership program that –  requires rental payments and any other fees that are not greater than those collected by the large institutional investor on other similarly situated single-family homes not covered by the eligible homeownership program; is subject to a contract between the large institutional investor and renter that shall be considered a consumer credit transaction secured by a dwelling or real property; provides for positive reporting of rental payments to consumer reporting agencies for any renter, who shall be informed of and opts into such reporting; and requires contribution of meaningful financial support from the large institutional investor, including price concessions, for the purchase of the single-family home by the renter;   Program to Boost Homeownership Pursuant to a program to boost homeownership that –  provides for positive reporting of rental payments to consumer reporting agencies for any renter who is informed of and opts into such reporting; provides for the right of first refusal and a 30-day ‘‘first look’’ period; and may entail the meaningful financial support from the large institutional investor, including price concessions, for the purchase of a single-family home by the renter (whether it is the home the renter occupies or another home);   Repossession In connection with the satisfaction of debts previously contracted in good faith and where the large institutional investor has the right to repossess the single-family home under such contract;   Foreclosure Undertaken by a mortgage servicer, lender, or other entity that has a legal right to a single-family home, for the purpose of loss mitigation or compliance with servicing or investor obligations, and not as a long-term investment strategy, and is solely as a result of –  a foreclosure; a deed-in-lieu of foreclosure; enforcement of a mortgage, deed of trust, or other security interest; or operation of law following borrower default;   Purchase from Another Large Institutional Investor Purchased from another large institutional investor that either owned the single-family home on the date of enactment of the Housing Act or purchased the single-family home in compliance with Section 1001;   Purchase from Investor Not a Large Institutional Investor Purchased from an investor not covered under Section 1001, so long as the purchase occurred not more than two years after the Effective Date;   Newly Constructed Single-Family Home in Senior Community Newly constructed, renovated, or a rental conversion that is intended and operated for occupancy as part of a community for households with one or more members aged 55 years or older, and satisfies visitability standards established by the HUD Secretary; or   Combination of Foregoing Purchases Purchased through a single purchase or combination or series of purchases described in the foregoing bullet points.   Large Institutional Investor:  The term “large institutional investor” means an investment fund, corporation, general or limited partnership, limited liability company, joint venture, association, or other for-profit entity that is a legal entity structured in a manner that is not aforementioned that –  is engaged, in whole or in part, in the business of investing in, owning, renting, managing, or holding single-family homes; and alone or in concert with one or more other entities, beginning after the date of enactment of the Housing Act, directly or indirectly has investment control of not less than 350 single-family homes in the aggregate, not including any single-family home purchased in an excepted purchase made after the date of enactment of the Housing Act.   A large institutional investor does not include any local, State, Tribal, or Federal government entity or instrumentality thereof. For purposes of the definition of “large institutional investor”, an entity has direct or indirect investment control over a single-family home if the entity –  owns, or has primary authority or fiduciary responsibility to make material investment or management decisions relating to, the single-family home; is, or directly or indirectly controls, the general partner or managing member of the entity that owns the single-family home; is or controls the investment manager, management company, or investment advisor of the entity that owns the single-family home; owns or controls more than 25% of any class of equity interests of the entity that owns the single-family home, unless such entity is a passive investor; or otherwise controls the entity that owns the single-family home.   Purchase:  The term “purchase” includes any purchase, transfer, or other acquisition of a single-family home, including through mergers, acquisitions, construction, foreclosures, or bulk purchases, whether or not for cash consideration.   Single-Family Home:  The term “single-family home” means a structure that contains two or fewer dwelling units that are each intended for residential occupancy by a single household.  The term “single-family home” does not include a manufactured home, as defined in section 603 of the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5402).
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44 Sullivan & Worcester Lawyers Selected as “Best Lawyers” Award Recipients
Boston, MA – Sullivan & Worcester today announced that 44 lawyers were recognized in the 2027 edition of Best Lawyers in America®. 40 of the firm’s lawyers in Boston, New York and Washington, D.C. were selected as “Best Lawyers in America®,” and four Sullivan lawyers were recognized as “Ones to Watch” in the U.S. Best Lawyers in America® The firm’s 2027 Best Lawyers in Boston include Victor Baltera (Environmental Law, Real Estate Law); Howard Berkenblit (Corporate Governance Law, Corporate Law); Harvey Bines (Corporate Compliance Law, Corporate Governance Law, Corporate Law); Ashley Brooks (Real Estate Law); Joel Carpenter (Tax Law); Henry Comstock, Jr. (Trusts and Estates); Christopher Curtis (Tax Law); Patrick Dinardo (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation - Bankruptcy); John Graham (Nonprofit / Charities Law, Tax Law); David Guadagnoli (Employee Benefits (ERISA) Law, Tax Law); Warren Heilbronner (Real Estate Law); Zachary Hyde (Patent Law); Richard Jones (Tax Law); Karen Kepler (Real Estate Law); Caroline Kupiec (Tax Law); Thomas Meyers (Patent Law); Lisa Mingolla (Trusts and Estates); Louis Monti (Real Estate Law); Cornelius Murray III (Trusts and Estates); David Nagle (Litigation and Controversy - Tax, Tax Law); Ameek Ashok Ponda (Tax Law); Gregory Sampson (Environmental Law, Land Use and Zoning Law, Real Estate Law); Lewis Segall (Corporate Law, Mergers and Acquisitions Law); Amy Sheridan (Employee Benefits (ERISA) Law, Tax Law); Laura Steinberg (Commercial Litigation); John Steiner (Real Estate Law); Douglas Stransky (Tax Law); Sarah Wellings (Tax Law); and Amy Zuccarello (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation - Bankruptcy). Sullivan’s 2027 Best Lawyers in Washington, D.C. include John Chilton (Mutual Funds Law); Cameron Cosby (Tax Law); Nicole Crum (Mutual Funds Law); David Leahy (Mutual Funds Law); David Mahaffey (Mutual Funds Law, Securities Regulation); and Stephanie Monaco (Corporate Law, Mutual Funds Law, Private Funds / Hedge Funds Law, Securities Regulation). The firm’s 2027 Best Lawyers in New York include Carole Bass (Trusts and Estates); J. Truman Bidwell, Jr. (Corporate Law); Domenick Pugliese (Mutual Funds Law); Constantine Ralli (Trusts and Estates); and Marc Stern (Trusts and Estates). Best Lawyers: Ones to Watch Awardees Best Lawyers awards this recognition to attorneys who are earlier in their careers for their outstanding professional excellence in private practice in the United States. Sullivan’s lawyers earning this award include Alexander Gansebom (Corporate Governance and Compliance Law, Corporate Law, Health Care Law, Mergers and Acquisitions Law, Real Estate Law); Emily Goldschmidt (Corporate Law); Ryan Rosenblatt (Commercial Litigation); and Ashley Tan (Real Estate Law). Best Lawyers Selection Methodology Recognition by Best Lawyers in America® is based on a peer review process designed to capture the consensus opinion of leading lawyers about the professional abilities of their colleagues within the same geographical and legal practice areas. About Sullivan Sullivan & Worcester (Sullivan) is a premier, AmLaw 200 international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
Top Tier Firm, Legal 500 United States 2026
Sullivan & Worcester Ranked in the Legal 500 United States 2026 Edition
Boston, MA – Sullivan & Worcester announced that its practice groups and attorneys have been ranked and recommended in the Legal 500 United States 2026. The firm’s Real Estate practice was newly ranked Tier 1 in the “Real estate – mid-market ($0-500m)” category and the firm maintained rankings across a variety of practice areas. Partners Nicole Crum and John Steiner were newly ranked as Leading Partners and Ryan Rosenblatt as a Next Generation Partner. Peers and more than 300,000 corporate counsel were surveyed and interviewed globally in the past 12 months to assess law firms’ overall visibility and reputation, culminating in detailed rankings and editorial. The Legal 500 is an independent guide, and firms and individuals are recommended purely on merit. Sullivan's lawyers received the following rankings: Leading Partners: The Legal 500’s Guide to Outstanding Lawyers Nationwide Benjamin Armour - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) Ameek Ashok Ponda - Real Estate Investment Trusts (REITs)  Nicole Crum - Mutual/registered/exchange-traded funds Lewis Segall - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) John Steiner - Real estate – mid-market ($0-500m) Douglas Stransky - International Tax Joel Telpner - Fintech Next Generation Partners: The Legal 500’s Guide to Up-and-Coming Lawyers Nationwide Ryan Rosenblatt - General commercial disputes – mid-market ($250-500m) Sarah Wellings - Real Estate Investment Trusts (REITs) Practice Areas Ranked and Attorneys Recognized Corporate Governance “Our lead partner, Nicole Crum, who leads the investment industry practice, is exceptional. She demonstrates strong industry knowledge yet is very personable and anticipates what we need to know or what we should consider doing to handle any matter. The team roll up their sleeves and provide recommendations as to how we as a board should handle any matter. Strong service commitment and work ethic!” “The team we have at Sullivan & Worcester has served our company for years and knows the management team, staff as well as our board members. They are extremely responsive and proactive and anticipate what we should be aware of, concerned about, excited about, and how to handle oversight, processes and protocols to ensure we are carrying out our fiduciary duties. The partners are experts in this industry.” Leading Partner: Nicole Crum Recommended Lawyers: Howard Berkenblit, David Leahy Dispute Resolution/General Commercial Disputes “Diverse skillset. Client centric. Transparency. Urgency provided on all matters.” “I have worked with Gerry Silver for over 15 years and have found his pragmatic approach to complex matters refreshing. He understands our business, culture and market, and will give me his opinion in a digestible manner.” Next Generation Partner: Ryan Rosenblatt Recommended Lawyers: Gerry Silver, Patrick Dinardo, Laura Steinberg, Michael Sullivan, Amy Zuccarello, Erika Todd, Christopher Shields, Anna Lea McNerney Employee Benefits, Executive Compensation and Retirement Plans: Design “The level of expertise is top shelf. David Guadagnoli seems to know all of ERISA and IRS rulings.” “David Guadagnoli and Amy Sheridan both have superior knowledge in their respective areas. I value the ability to raise issues whether simple or complex. The firm takes the same diligent approach across all spectrums of complexity.” Recommended Lawyers: David Guadagnoli, Amy Sheridan Environment: Transactional Fintech “Sullivan & Worcester is one of the finest firms with which I have worked.” “The lawyers are excellent, and the firm consistently provides the highest quality of customer service.” Leading Partner: Joel Telpner Recommended Lawyers: Natalie Lederman, Benjamin Armour, Scott Kaufman, Harvey Bines, Christopher Curtis Land Use/Zoning Recommended Lawyers: Gregory Sampson, Ashley Brooks, Victor Baltera, Karen Kepler, Ashley Tan M&A: Corporate and Commercial: Venture Capital and Emerging Companies Recommended Lawyers: Scott Kaufman, Lewis Segall, Benjamin Armour, Michael Student M&A: Middle-Market ($0-250m) “The partner Lewis Segall has been working with our company for 15 years and we have a good working relationship with him. He knows our history and very attentive to our needs.” “Lewis Segall is very attentive to our needs. We very much value him.” Leading Partners: Benjamin Armour, Lewis Segall Recommended Lawyers: Natalie Lederman Mutual/Registered/Exchange-Traded Funds “Sullivan & Worcester's practice is defined by its deep expertise in investment funds and its ability to deliver clear, commercially grounded advice across the full fund lifecycle—from formation and structuring to regulatory compliance and complex transactions.” “The team is highly experienced, collaborative, and excel in efficient execution and clear communication.” Leading Partner: Nicole Crum Recommended Lawyers: David Leahy, David Mahaffey, Rachael Schwartz Real Estate Leading Partner: John Steiner Recommended Lawyers: Ashley Brooks, Karen Kepler, Gregory Sampson, Sharon Leifer, Louis Monti, Spencer Stone, Ashley Tan Real Estate Investment Trusts (REITs) “We have built multiple complex and sophisticated REIT platforms over the years and worked with many top-tier REIT specialists, but Sullivan’s REIT practice is by far the best, with Sarah Wellings.” Leading Partner: Ameek Ashok Ponda Next Generation Partner: Sarah Wellings Recommended Lawyers: Angela Gomes, Louis Monti, Shu Wei, Cameron Cosby International Tax “The international collaboration with S&W is exceptional.” “What really stands out is their willingness to engage, openness to different ideas and opinions, clearly expressed expectations, and clients' objectives.” Leading Partner: Douglas Stransky Recommended Lawyers: Lewis Greenwald, Eric Rietveld Tax > US Taxes: Contentious Recommended Lawyers: Richard Jones, David Nagle, Daniel Ryan, Caroline Kupiec Tax > US Taxes: Non-Contentious “Sarah Wellings is, quite simply, the best lawyer we have ever worked with. Her expertise extends far beyond tax and REIT matters, encompassing governance, financing, and complex commercial issues. Decades of experience and technical mastery make her an indispensable partner. Sarah is our central point of contact who makes everything seamless. Her in-house counsel background gives her a unique client perspective: she anticipates needs, solves problems before they arise, and delivers concise, well-structured updates that simplify even the most intricate issues. She coordinates effortlessly with all parties involved. Her judgment is exceptional. Sarah strikes the perfect balance between comprehensive academic rigor and practical, business-oriented advice. She combines technical REIT/tax excellence with commercial instincts, ensuring every recommendation is both legally sound and strategically smart. Her ability to translate complex law into clear, actionable guidance is unmatched. Sarah is incredibly responsive without ever sacrificing quality. She treats our matters as her own, demonstrating a rare ownership mindset and collaborative spirit. Her integrity is uncompromising, giving us absolute confidence in her counsel. In short, Sarah Wellings defines legal excellence: reliable, commercially minded, and client-focused. Working with her feels like being in the safest possible hands; she consistently exceeds expectations and orchestrates complex transactions with clarity and precision.” Recommended Lawyers: Ameek Ashok Ponda, Richard Jones, Douglas Stransky, Sarah Wellings About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.

Sarah D. Wellings

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

Sarah D. Wellings

August 20, 2026

–Press Release

44 Sullivan & Worcester Lawyers Selected as “Best Lawyers” Award Recipients

June 15, 2026

–Press Release

Sullivan & Worcester Ranked in the Legal 500 United States 2026 Edition

Top Tier Firm, Legal 500 United States 2026

June 4, 2026

–Press Release

Sullivan & Worcester Ranked in Chambers USA 2026 Edition

August 21, 2025

–Press Release

44 Sullivan & Worcester Lawyers Named as “Best Lawyers” Award Recipients

Three Lawyers Recognized as “2026 Lawyer of the Year” and Five Recognized Among “Ones to Watch” in the U.S.

July 16, 2025

–Quoted

Attys Tout 3 Real Estate Investment Wins In Federal Budget

Law360 Real Estate Authority

June 13, 2025

–Press Release

Sullivan & Worcester Ranked in the Legal 500 United States 2025 Edition

June 5, 2025

–Press Release

Sullivan & Worcester Ranked in Chambers USA 2025 Edition

August 2, 2024

–Press Release

Sullivan REIT and Tax Teams Advise on $250 Million American Tower-Stonepeak Joint Venture

June 12, 2024

–Press Release

Sullivan Earns Top Rankings in the 2024 Edition of The Legal 500 United States

January 8, 2024

–Press Release

Sullivan & Worcester Elevates Four to Partnership in U.S. & Israel

New Partners Represent Corporate, Compliance, Litigation and Tax Practices

September 9, 2022

–Press Release

Sullivan Bolsters REIT Group, Welcomes Sarah Wellings Back to Firm as Counsel

Sarah D. Wellings

October 13, 2026

–Publication

Remediation of M&A REIT Targets

July 13, 2026

–Client Alert

Impact of 21st Century ROAD to Housing Act on Institutional Investor Ownership of Single-Family Rental Homes

May 26, 2026

–Memorandum

Selected REIT Tax Issues in Constructing a Data Center

April 27, 2026

–Video

Sullivan & Worcester Partner Sees TRS Structure as Simpler, More Flexible Alternative for REITs

Nareit

July 7, 2025

–Client Alert

Final REIT-Related Provisions in the “One Big Beautiful Bill Act”

June 23, 2025

–Client Alert

Senate Finance Changes to REIT-Related Provisions in the “One Big Beautiful Bill Act”

June 9, 2025

–Publication

Sullivan & Worcester Submits Comments to IRS Urging Caution in Applying Cloud Transaction Framework to REIT Rules

June 2, 2025

–Publication

Remediation of M&A REIT Targets

IRS's PLR 202440007

May 27, 2025

–Client Alert

How REITs are Impacted by the “One Big Beautiful Bill Act”

December 2, 2024

–Interview

How I Made Partner: 'Prioritize What Is Important to You, Do What Energizes You,' Says Sarah Wellings of Sullivan & Worcester

Law.com

October 15, 2024

Remediation of M&A REIT Targets

IRS's PLR 202440007

June 25, 2024

–Publication

Real Estate Investment Trusts 2024 - USA

Lexology Getting the Deal Through

April 18, 2024

–Publication

Ameek Ashok Ponda Submits Comments to IRS to Address Favorably REITs Deploying Renewable Energy Infrastructure at their Properties

March 4, 2024 (Updated April 18, 2024)

–Publication

Enabling REITs to Deploy Renewable Energy: Toward a Workable Legal Standard

March 28, 2011

–Publication

The Scope of Work Product in Massachusetts Tax Controversies

Tax Notes

July 13, 2009

–Publication

Massachusetts Finalizes Combined Reporting Regulations

Tax Notes

February 9, 2009

–Publication

New Regs Set the Framework for Combined Reporting in Massachusetts

Tax Notes

September 15, 2008

–Publication

Radical Tax Changes on the Horizon For Massachusetts

Tax Notes

July 21, 2008

–Publication

Massachusetts Combined Reporting Proposal Survives Study And Becomes Law

Tax Notes

Sarah D. Wellings

Sarah is co-leader of Sullivan’s REITs Practice Group. She advises public and private REITs, both domestic and foreign, in various industries, including data centers, office buildings, commercial retail space, hospitality, multi-family residential, senior living facilities, cold storage facilities, industrial properties, communications towers, distributed antenna systems, timberlands and agricultural properties. She focuses on structuring and compliance work, including cross-border transactions.

In addition, Sarah advises clients in state and local tax transactional planning and litigation involving corporate, franchise, and sales/use tax matters. Sarah also has experience in advising tax-exempt organizations, including public charities, on all aspects of operations.

Sarah is an adjunct professor with the Villanova University Charles Widger School of Law Graduate Tax Program, where for over 12 years she has taught tax courses on state and local tax planning and state and local tax controversy.

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Remediation of M&A REIT Targets
Ameek Ashok Ponda, Sarah Wellings and Connie Lee updated their white paper, "Remediation of M&A REIT Targets," for additional administrative authorities, deal precedents, and recent case law. The white paper was published most recently by Practising Law Institute’s “Real Estate M&A and REIT Transactions” as part of its 2024 Real Estate Practice Course Handbook Series and serves as the playbook for diligencing and remediating real or perceived REIT qualification failures.
Impact of 21st Century ROAD to Housing Act on Institutional Investor Ownership of Single-Family Rental Homes
The U.S. Congress passed the 21st Century ROAD to Housing Act (the “Housing Act”) and presented it to President Trump on June 29, 2026. At midnight on July 10, 2026, the Housing Act became law because the President did not return it to Congress within ten days (Sundays excepted). The Housing Act includes a wide range of housing reforms designed with the goal of making housing more available and affordable.  This alert focuses on the impact of the Housing Act on institutional investor ownership of single-family rental homes.  The Housing Act does not prohibit institutional investor ownership of manufactured homes. The section of the Housing Act impacting institutional investor ownership of single-family rental homes is Section 1001 (the Section is titled “Homes Are for People, Not Corporations”).  The primary impacts under Section 1001 are (i) a prohibition on purchases of single-family homes (with important exceptions) and (ii) the creation of a “Renter Outreach Resource” managed by the federal government.  Section 1001 uses a number of defined terms, which are summarized in Appendix A to this alert.  The defined terms are indicated in this alert in italics.  The most important – and most extensive – defined term is excepted purchase, which includes, among other programs, purchases of single-family homes pursuant to build-to-rent programs and purchases of single-family homes from other large institutional investors. No Requirement to Dispose When the U.S. Senate passed a version of the Housing Act in March 2026, the legislation included a controversial, perhaps even unconstitutional, provision requiring institutional investors to dispose of certain single-family homes not later than seven years after the date of purchase.  A relief to such institutional investors, the Housing Act, as enacted, does not include that requirement to dispose. Prohibition on Purchases (with Several Exceptions) The Housing Act prohibits the purchase of single-family homes by large institutional investors, excluding any excepted purchase or any purchase of a single-family home in connection with a restructuring or other reorganization of ownership of single-family homes that were owned or purchased on or before the date of enactment of the Housing Act.  The prohibition on purchases takes effect on January 7, 2027 (180 days after the date of enactment of the Housing Act) (the “Effective Date”) and is repealed on January 7, 2042 (15 years after the Effective Date). Excepted purchases (i.e., those not prohibited) are described in detail in Appendix A under the defined term “Excepted Purchase”, but generally include many of the common methods by which institutional investors in single-family rental homes acquire such homes, including but not limited to: (i) build‑to‑rent programs, (ii) renovate‑to‑rent programs, (iii) repossessions, (iv) foreclosures, (v) purchases from another large institutional investor, or (vi) combinations of (i) through (v). Enforcement of Prohibition on Purchases The Secretary of the Treasury, or the Attorney General at the request of the Secretary of the Treasury, may bring an action against a large institutional investor that violates the prohibition on purchases for a civil penalty in an amount that is not more than $1,000,000 per violation, or three times the purchase price of the property involved, whichever is greater. Renter Outreach Resource As described in detail below, the Renter Outreach Resource is a comprehensive program that includes direct reporting of rental disputes by renters to Federal agencies, with investigation and reporting requirements imposed on applicable Federal agencies, and (at a minimum) provision of applicable state agency contact information to renters to facilitate state-level investigation.  In addition, large institutional investors must respond to information requests in connection with any investigation and are required to regularly provide certain information regarding the Renter Outreach Resource to their renters. Establishment of Renter Outreach Resource The Secretary of Housing and Urban Development (the “HUD Secretary”) is required, not later than 180 days after the date of enactment of the Housing Act, to establish the Renter Outreach Resource that consists of a toll-free telephone number and a public website designed to assist renters of residential properties owned by a large institutional investor in –  notifying Federal agencies about disputes relating to the rental of such properties, including disputes about potential violations of Federal law; sharing information about such disputes with other Federal agencies, including other Federal agencies that manage similar disputes; monitoring such disputes; and resolving such disputes, to the extent practicable.   Response to Outreach The HUD Secretary is required to establish reasonable procedures to promptly respond, in writing where appropriate, to a renter who provides information to the HUD Secretary about a dispute using the Renter Outreach Resource and document such responses.  Such responses are required to include, where appropriate, information about –  steps that have been taken by the HUD Secretary or another Federal agency in response to the information about the dispute provided by the renter, including determining the appropriate large institutional investor involved as described in the bullet below “Investigation of Potential Violations of Federal Law;” any responses received by the HUD Secretary or another Federal agency from the large institutional investor related to such dispute; and any outcome of the dispute, to the extent practicable.   Investigation of Potential Violations of Federal Law The HUD Secretary is required to promptly process and investigate any information relating to a dispute received through the Renter Outreach Resource about a potential violation of Federal law that is received from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, including –  requesting information from a large institutional investor; determining the appropriate large institutional investor involved in the dispute; and sharing information about such potential violation of Federal law with any relevant Federal agencies, as the HUD Secretary may determine appropriate.   Upon request for information made pursuant to the Renter Outreach Resource, the HUD Secretary is required to provide a large institutional investor the opportunity to respond, including regarding whether such large institutional investor currently owns the property described in such request for information.   Information for Appropriate State Authority When the HUD Secretary receives information about a potential violation of State law or about a dispute received through the Renter Outreach Resource, from a renter of a residential property owned by a large institutional investor through the Renter Outreach Resource, the HUD Secretary is required, at a minimum, to provide the renter with contact information for the appropriate, State-specific, State authority authorized to process and investigate such information.   Notice About Renter Outreach Resource Each large institutional investor is required to –  provide to each renter of a residential property owned by such investor at the time such renter first occupies such home and annually thereafter –  written notice about the Renter Outreach Resource; and the name, phone number, and email address of the person or entity responsible for receiving and addressing renter disputes for the large institutional investor, and update the name, phone number, and email address within 30 days if such information changes prior to the subsequent time at which such notice is required to be provided; and   prominently feature information about the Renter Outreach Resource on a public website of such investor that is accessible by such renter.   Annual Notification Not later than 180 days after the date of enactment of the Housing Act, and not later than December 31st of each year thereafter, each person or entity that satisfies the definition of a large institutional investor is required to –  notify the HUD Secretary each year whether such owner is a large institutional investor; and in such notification, identify how many single-family homes such large institutional investor has direct or indirect investment control of as of the date of the submission of such notice, and the city and State where each such single-family home is located, unless such large institutional investor owns ten or fewer single-family homes in such city. Studies on Large Institutional Investors Not later than two years after the Effective Date, and again not later than ten years after the Effective Date, a GAO report and a HUD report are required to be submitted to the House Banking Committee and the Senate Committee on Financial Services. *     *     * Contacts Tax Cameron N. Cosby Carson Durdel Connie Lee Ameek Ashok Ponda Sarah D. Wellings Private Funds William C. Hanson Real Estate Karen J. Kepler Louis A. Monti John M. Steiner Appendix A Defined Terms in Section 1001 of the Housing Act Consumer Reporting Agency:  The term “consumer reporting agency” has the meaning given the term in section 603 of the Fair Credit Reporting Act (15 U.S.C. 1681a)). Excepted Purchase:  The term “excepted purchase” means any purchase of a single-family home that is –  Newly Constructed, For Sale Home Newly constructed, renovated, or a rental conversion for sale by a large institutional investor and not as a residence rented pending sale;   Build-to-Rent Program Pursuant to a build-to-rent program where the large institutional investor purchases newly constructed single-family homes to be managed as rental properties, whether as communities exclusively of renter-occupied single-family homes or as communities of single-family homes that are both owner- and renter-occupied;   Renovate-to-Rent Program Pursuant to a renovate-to-rent program that –  substantially rehabilitates single-family homes that do not meet structural or core system elements of local building codes; and makes improvements in an aggregate dollar amount of not less than 15% of the purchase price of the single-family home;   Homeownership Program Pursuant to a homeownership program that –  requires rental payments and any other fees that are not greater than those collected by the large institutional investor on other similarly situated single-family homes not covered by the eligible homeownership program; is subject to a contract between the large institutional investor and renter that shall be considered a consumer credit transaction secured by a dwelling or real property; provides for positive reporting of rental payments to consumer reporting agencies for any renter, who shall be informed of and opts into such reporting; and requires contribution of meaningful financial support from the large institutional investor, including price concessions, for the purchase of the single-family home by the renter;   Program to Boost Homeownership Pursuant to a program to boost homeownership that –  provides for positive reporting of rental payments to consumer reporting agencies for any renter who is informed of and opts into such reporting; provides for the right of first refusal and a 30-day ‘‘first look’’ period; and may entail the meaningful financial support from the large institutional investor, including price concessions, for the purchase of a single-family home by the renter (whether it is the home the renter occupies or another home);   Repossession In connection with the satisfaction of debts previously contracted in good faith and where the large institutional investor has the right to repossess the single-family home under such contract;   Foreclosure Undertaken by a mortgage servicer, lender, or other entity that has a legal right to a single-family home, for the purpose of loss mitigation or compliance with servicing or investor obligations, and not as a long-term investment strategy, and is solely as a result of –  a foreclosure; a deed-in-lieu of foreclosure; enforcement of a mortgage, deed of trust, or other security interest; or operation of law following borrower default;   Purchase from Another Large Institutional Investor Purchased from another large institutional investor that either owned the single-family home on the date of enactment of the Housing Act or purchased the single-family home in compliance with Section 1001;   Purchase from Investor Not a Large Institutional Investor Purchased from an investor not covered under Section 1001, so long as the purchase occurred not more than two years after the Effective Date;   Newly Constructed Single-Family Home in Senior Community Newly constructed, renovated, or a rental conversion that is intended and operated for occupancy as part of a community for households with one or more members aged 55 years or older, and satisfies visitability standards established by the HUD Secretary; or   Combination of Foregoing Purchases Purchased through a single purchase or combination or series of purchases described in the foregoing bullet points.   Large Institutional Investor:  The term “large institutional investor” means an investment fund, corporation, general or limited partnership, limited liability company, joint venture, association, or other for-profit entity that is a legal entity structured in a manner that is not aforementioned that –  is engaged, in whole or in part, in the business of investing in, owning, renting, managing, or holding single-family homes; and alone or in concert with one or more other entities, beginning after the date of enactment of the Housing Act, directly or indirectly has investment control of not less than 350 single-family homes in the aggregate, not including any single-family home purchased in an excepted purchase made after the date of enactment of the Housing Act.   A large institutional investor does not include any local, State, Tribal, or Federal government entity or instrumentality thereof. For purposes of the definition of “large institutional investor”, an entity has direct or indirect investment control over a single-family home if the entity –  owns, or has primary authority or fiduciary responsibility to make material investment or management decisions relating to, the single-family home; is, or directly or indirectly controls, the general partner or managing member of the entity that owns the single-family home; is or controls the investment manager, management company, or investment advisor of the entity that owns the single-family home; owns or controls more than 25% of any class of equity interests of the entity that owns the single-family home, unless such entity is a passive investor; or otherwise controls the entity that owns the single-family home.   Purchase:  The term “purchase” includes any purchase, transfer, or other acquisition of a single-family home, including through mergers, acquisitions, construction, foreclosures, or bulk purchases, whether or not for cash consideration.   Single-Family Home:  The term “single-family home” means a structure that contains two or fewer dwelling units that are each intended for residential occupancy by a single household.  The term “single-family home” does not include a manufactured home, as defined in section 603 of the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5402).
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44 Sullivan & Worcester Lawyers Selected as “Best Lawyers” Award Recipients
Boston, MA – Sullivan & Worcester today announced that 44 lawyers were recognized in the 2027 edition of Best Lawyers in America®. 40 of the firm’s lawyers in Boston, New York and Washington, D.C. were selected as “Best Lawyers in America®,” and four Sullivan lawyers were recognized as “Ones to Watch” in the U.S. Best Lawyers in America® The firm’s 2027 Best Lawyers in Boston include Victor Baltera (Environmental Law, Real Estate Law); Howard Berkenblit (Corporate Governance Law, Corporate Law); Harvey Bines (Corporate Compliance Law, Corporate Governance Law, Corporate Law); Ashley Brooks (Real Estate Law); Joel Carpenter (Tax Law); Henry Comstock, Jr. (Trusts and Estates); Christopher Curtis (Tax Law); Patrick Dinardo (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation - Bankruptcy); John Graham (Nonprofit / Charities Law, Tax Law); David Guadagnoli (Employee Benefits (ERISA) Law, Tax Law); Warren Heilbronner (Real Estate Law); Zachary Hyde (Patent Law); Richard Jones (Tax Law); Karen Kepler (Real Estate Law); Caroline Kupiec (Tax Law); Thomas Meyers (Patent Law); Lisa Mingolla (Trusts and Estates); Louis Monti (Real Estate Law); Cornelius Murray III (Trusts and Estates); David Nagle (Litigation and Controversy - Tax, Tax Law); Ameek Ashok Ponda (Tax Law); Gregory Sampson (Environmental Law, Land Use and Zoning Law, Real Estate Law); Lewis Segall (Corporate Law, Mergers and Acquisitions Law); Amy Sheridan (Employee Benefits (ERISA) Law, Tax Law); Laura Steinberg (Commercial Litigation); John Steiner (Real Estate Law); Douglas Stransky (Tax Law); Sarah Wellings (Tax Law); and Amy Zuccarello (Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law, Litigation - Bankruptcy). Sullivan’s 2027 Best Lawyers in Washington, D.C. include John Chilton (Mutual Funds Law); Cameron Cosby (Tax Law); Nicole Crum (Mutual Funds Law); David Leahy (Mutual Funds Law); David Mahaffey (Mutual Funds Law, Securities Regulation); and Stephanie Monaco (Corporate Law, Mutual Funds Law, Private Funds / Hedge Funds Law, Securities Regulation). The firm’s 2027 Best Lawyers in New York include Carole Bass (Trusts and Estates); J. Truman Bidwell, Jr. (Corporate Law); Domenick Pugliese (Mutual Funds Law); Constantine Ralli (Trusts and Estates); and Marc Stern (Trusts and Estates). Best Lawyers: Ones to Watch Awardees Best Lawyers awards this recognition to attorneys who are earlier in their careers for their outstanding professional excellence in private practice in the United States. Sullivan’s lawyers earning this award include Alexander Gansebom (Corporate Governance and Compliance Law, Corporate Law, Health Care Law, Mergers and Acquisitions Law, Real Estate Law); Emily Goldschmidt (Corporate Law); Ryan Rosenblatt (Commercial Litigation); and Ashley Tan (Real Estate Law). Best Lawyers Selection Methodology Recognition by Best Lawyers in America® is based on a peer review process designed to capture the consensus opinion of leading lawyers about the professional abilities of their colleagues within the same geographical and legal practice areas. About Sullivan Sullivan & Worcester (Sullivan) is a premier, AmLaw 200 international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
Top Tier Firm, Legal 500 United States 2026
Sullivan & Worcester Ranked in the Legal 500 United States 2026 Edition
Boston, MA – Sullivan & Worcester announced that its practice groups and attorneys have been ranked and recommended in the Legal 500 United States 2026. The firm’s Real Estate practice was newly ranked Tier 1 in the “Real estate – mid-market ($0-500m)” category and the firm maintained rankings across a variety of practice areas. Partners Nicole Crum and John Steiner were newly ranked as Leading Partners and Ryan Rosenblatt as a Next Generation Partner. Peers and more than 300,000 corporate counsel were surveyed and interviewed globally in the past 12 months to assess law firms’ overall visibility and reputation, culminating in detailed rankings and editorial. The Legal 500 is an independent guide, and firms and individuals are recommended purely on merit. Sullivan's lawyers received the following rankings: Leading Partners: The Legal 500’s Guide to Outstanding Lawyers Nationwide Benjamin Armour - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) Ameek Ashok Ponda - Real Estate Investment Trusts (REITs)  Nicole Crum - Mutual/registered/exchange-traded funds Lewis Segall - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) John Steiner - Real estate – mid-market ($0-500m) Douglas Stransky - International Tax Joel Telpner - Fintech Next Generation Partners: The Legal 500’s Guide to Up-and-Coming Lawyers Nationwide Ryan Rosenblatt - General commercial disputes – mid-market ($250-500m) Sarah Wellings - Real Estate Investment Trusts (REITs) Practice Areas Ranked and Attorneys Recognized Corporate Governance “Our lead partner, Nicole Crum, who leads the investment industry practice, is exceptional. She demonstrates strong industry knowledge yet is very personable and anticipates what we need to know or what we should consider doing to handle any matter. The team roll up their sleeves and provide recommendations as to how we as a board should handle any matter. Strong service commitment and work ethic!” “The team we have at Sullivan & Worcester has served our company for years and knows the management team, staff as well as our board members. They are extremely responsive and proactive and anticipate what we should be aware of, concerned about, excited about, and how to handle oversight, processes and protocols to ensure we are carrying out our fiduciary duties. The partners are experts in this industry.” Leading Partner: Nicole Crum Recommended Lawyers: Howard Berkenblit, David Leahy Dispute Resolution/General Commercial Disputes “Diverse skillset. Client centric. Transparency. Urgency provided on all matters.” “I have worked with Gerry Silver for over 15 years and have found his pragmatic approach to complex matters refreshing. He understands our business, culture and market, and will give me his opinion in a digestible manner.” Next Generation Partner: Ryan Rosenblatt Recommended Lawyers: Gerry Silver, Patrick Dinardo, Laura Steinberg, Michael Sullivan, Amy Zuccarello, Erika Todd, Christopher Shields, Anna Lea McNerney Employee Benefits, Executive Compensation and Retirement Plans: Design “The level of expertise is top shelf. David Guadagnoli seems to know all of ERISA and IRS rulings.” “David Guadagnoli and Amy Sheridan both have superior knowledge in their respective areas. I value the ability to raise issues whether simple or complex. The firm takes the same diligent approach across all spectrums of complexity.” Recommended Lawyers: David Guadagnoli, Amy Sheridan Environment: Transactional Fintech “Sullivan & Worcester is one of the finest firms with which I have worked.” “The lawyers are excellent, and the firm consistently provides the highest quality of customer service.” Leading Partner: Joel Telpner Recommended Lawyers: Natalie Lederman, Benjamin Armour, Scott Kaufman, Harvey Bines, Christopher Curtis Land Use/Zoning Recommended Lawyers: Gregory Sampson, Ashley Brooks, Victor Baltera, Karen Kepler, Ashley Tan M&A: Corporate and Commercial: Venture Capital and Emerging Companies Recommended Lawyers: Scott Kaufman, Lewis Segall, Benjamin Armour, Michael Student M&A: Middle-Market ($0-250m) “The partner Lewis Segall has been working with our company for 15 years and we have a good working relationship with him. He knows our history and very attentive to our needs.” “Lewis Segall is very attentive to our needs. We very much value him.” Leading Partners: Benjamin Armour, Lewis Segall Recommended Lawyers: Natalie Lederman Mutual/Registered/Exchange-Traded Funds “Sullivan & Worcester's practice is defined by its deep expertise in investment funds and its ability to deliver clear, commercially grounded advice across the full fund lifecycle—from formation and structuring to regulatory compliance and complex transactions.” “The team is highly experienced, collaborative, and excel in efficient execution and clear communication.” Leading Partner: Nicole Crum Recommended Lawyers: David Leahy, David Mahaffey, Rachael Schwartz Real Estate Leading Partner: John Steiner Recommended Lawyers: Ashley Brooks, Karen Kepler, Gregory Sampson, Sharon Leifer, Louis Monti, Spencer Stone, Ashley Tan Real Estate Investment Trusts (REITs) “We have built multiple complex and sophisticated REIT platforms over the years and worked with many top-tier REIT specialists, but Sullivan’s REIT practice is by far the best, with Sarah Wellings.” Leading Partner: Ameek Ashok Ponda Next Generation Partner: Sarah Wellings Recommended Lawyers: Angela Gomes, Louis Monti, Shu Wei, Cameron Cosby International Tax “The international collaboration with S&W is exceptional.” “What really stands out is their willingness to engage, openness to different ideas and opinions, clearly expressed expectations, and clients' objectives.” Leading Partner: Douglas Stransky Recommended Lawyers: Lewis Greenwald, Eric Rietveld Tax > US Taxes: Contentious Recommended Lawyers: Richard Jones, David Nagle, Daniel Ryan, Caroline Kupiec Tax > US Taxes: Non-Contentious “Sarah Wellings is, quite simply, the best lawyer we have ever worked with. Her expertise extends far beyond tax and REIT matters, encompassing governance, financing, and complex commercial issues. Decades of experience and technical mastery make her an indispensable partner. Sarah is our central point of contact who makes everything seamless. Her in-house counsel background gives her a unique client perspective: she anticipates needs, solves problems before they arise, and delivers concise, well-structured updates that simplify even the most intricate issues. She coordinates effortlessly with all parties involved. Her judgment is exceptional. Sarah strikes the perfect balance between comprehensive academic rigor and practical, business-oriented advice. She combines technical REIT/tax excellence with commercial instincts, ensuring every recommendation is both legally sound and strategically smart. Her ability to translate complex law into clear, actionable guidance is unmatched. Sarah is incredibly responsive without ever sacrificing quality. She treats our matters as her own, demonstrating a rare ownership mindset and collaborative spirit. Her integrity is uncompromising, giving us absolute confidence in her counsel. In short, Sarah Wellings defines legal excellence: reliable, commercially minded, and client-focused. Working with her feels like being in the safest possible hands; she consistently exceeds expectations and orchestrates complex transactions with clarity and precision.” Recommended Lawyers: Ameek Ashok Ponda, Richard Jones, Douglas Stransky, Sarah Wellings About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
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Viewpoints
Geoffrey Wynne Discusses the Future of Trade Finance Education in the Age of AI

Geoffrey Wynne, partner at Sullivan & Worcester and head of its Trade & Export Finance Group, joined Alex Gray, Director of Trade and Transaction Banking at the London Institute of Banking and Finance (LIBF), for a discussion with Eleonore Treu, Director of Trade Finance Week at ICC Austria, at the ITFA Annual Conference in Split, Croatia. The conversation explored how artificial intelligence is changing the skills required in trade finance, the

Events
61st Annual Heckerling Institute on Estate Planning

Carole Bass will participate in two presentations at the 61st Annual Heckerling Institute on Estate Planning, held at the Orlando World Center Marriott in Orlando, Florida, from January 11-15, 2027. Founded at the University of Miami School of Law, the Heckerling Institute on Estate Planning is the country’s leading provider of quality estate planning education and the national gathering place for estate planning professionals. The first presentation, "Who’s in the Control Tower? Helicopter

Viewpoints
Who Lends to Commodity Borrowers Without a Track Record?

Geoffrey Wynne has contributed to an article for Trade Treasury Payments (TTP), by Eleanor Hill, titled “Who Lends to Commodity Borrowers Without a Track Record?”, following the second 2026 Sullivan and TTP co-hosted Trade and Commodity Finance Breakfast Club, held on Tuesday, 15 September at The Lansdowne Club in London. The discussion, which was moderated by Geoff, featured Tanya Epshteyn at Czarnikow Group, James Lowrey at Lloyds Bank and John MacNamara

News
Sullivan’s Trade Finance and Venture Capital Practices Recognised by Chambers UK 2027

London, UK - International law firm Sullivan & Worcester (Sullivan) has been recognised in the Chambers UK 2027 guide, with leading rankings for its Trade & Export Finance practice and individual recognition for lawyers across its London Trade Finance and Emerging Companies & Venture Capital teams. Sullivan’s Trade & Export Finance practice has retained its Band 1 ranking in the UK-wide Commodities: Trade Finance category for the third consecutive year, reinforcing its

Events
Slush 2026

Sullivan & Worcester will once again participate in Slush 2026, taking place November 18-19 in Helsinki, Finland. One of the world's leading startup events, Slush brings together entrepreneurs and investors from around the globe, offering a unique opportunity to connect with the Nordic technology community and explore new business opportunities. Representing the firm's Emerging Companies & Venture Capital, Intellectual Property and Mergers & Acquisitions practices, Sullivan's team will include Scott Kaufman, Mike Palmisciano, Michael

Events
Looking ahead or back to basics? ECA reform priorities to remain competitive

Partner Mark Norris⁠ will participate in GTR Africa 2026 London, hosted by Global Trade Review (GTR) on November 12, the theme for which is “Charting Africa’s trade and export trajectory.” Mark will join the panel discussing “Looking ahead or back to basics? ECA reform priorities to remain competitive”, which will be moderated by Chris Mitman at Acre Impact Capital and include Ram Shalita at Bluebird Finance & Projects and Anders Vium

News
How Supreme Court Justices Are Leaning In Major 401(k) Case Over Private Funds and Underperformance

Harvey Bines was quoted in the article "How Supreme Court Justices Are Leaning In Major 401(k) Case Over Private Funds and Underperformance," published by cnbc.com on October 10, 2026. The article discusses growing interest in adding private investments to 401(k) plans as employers await a Supreme Court ruling and new Department of Labor rules that could shape plan design and fiduciary oversight. Harvey notes, “There’s a clear business case for making

Viewpoints
SEC Proposes New Crypto Custody Framework for Registered Investment Advisers and Regulated Funds

On October 1, 2026, the U.S. Securities and Exchange Commission (the "SEC") proposed a comprehensive new custody framework for crypto assets. Subject to significant conditions, the proposal would permit SEC-registered investment advisers to self-custody certain client crypto assets when no qualified custodian is reasonably available for the particular asset. It also would permit registered investment companies and business development companies ("BDCs," and together with registered investment companies, "regulated funds") to

News
Sullivan Expands London Trade & Export Finance Practice with Addition of Veronika Koroleva as Counsel

Sullivan & Worcester (Sullivan) has welcomed Veronika Koroleva as counsel in its market-leading Trade & Export Finance practice in London. Joining from Hill Dickinson, where she was Head of Trade Finance, Veronika brings extensive experience in trade and commodity finance, including structured trade, receivables and supply chain finance. Veronika’s arrival builds on the expansion of the practice following the additions of Robert Parson and Matthew Cox as partners in 2025 and

Viewpoints
Remediation of M&A REIT Targets

Ameek Ashok Ponda, Sarah Wellings and Connie Lee updated their white paper, "Remediation of M&A REIT Targets," for additional administrative authorities, deal precedents, and recent case law. The white paper was published most recently by Practising Law Institute’s “Real Estate M&A and REIT Transactions” as part of its 2024 Real Estate Practice Course Handbook Series and serves as the playbook for diligencing and remediating real or perceived REIT qualification failures.

Viewpoints
Geoffrey Wynne Discusses the Future of Trade Finance Education in the Age of AI

Geoffrey Wynne, partner at Sullivan & Worcester and head of its Trade & Export Finance Group, joined Alex Gray, Director of Trade and Transaction Banking at the London Institute of Banking and Finance (LIBF), for a discussion with Eleonore Treu, Director of Trade Finance Week at ICC Austria, at the ITFA Annual Conference in Split, Croatia. The conversation explored how artificial intelligence is changing the skills required in trade finance, the

Events
61st Annual Heckerling Institute on Estate Planning

Carole Bass will participate in two presentations at the 61st Annual Heckerling Institute on Estate Planning, held at the Orlando World Center Marriott in Orlando, Florida, from January 11-15, 2027. Founded at the University of Miami School of Law, the Heckerling Institute on Estate Planning is the country’s leading provider of quality estate planning education and the national gathering place for estate planning professionals. The first presentation, "Who’s in the Control Tower? Helicopter

Viewpoints
Who Lends to Commodity Borrowers Without a Track Record?

Geoffrey Wynne has contributed to an article for Trade Treasury Payments (TTP), by Eleanor Hill, titled “Who Lends to Commodity Borrowers Without a Track Record?”, following the second 2026 Sullivan and TTP co-hosted Trade and Commodity Finance Breakfast Club, held on Tuesday, 15 September at The Lansdowne Club in London. The discussion, which was moderated by Geoff, featured Tanya Epshteyn at Czarnikow Group, James Lowrey at Lloyds Bank and John MacNamara

News
Sullivan’s Trade Finance and Venture Capital Practices Recognised by Chambers UK 2027

London, UK - International law firm Sullivan & Worcester (Sullivan) has been recognised in the Chambers UK 2027 guide, with leading rankings for its Trade & Export Finance practice and individual recognition for lawyers across its London Trade Finance and Emerging Companies & Venture Capital teams. Sullivan’s Trade & Export Finance practice has retained its Band 1 ranking in the UK-wide Commodities: Trade Finance category for the third consecutive year, reinforcing its

Events
Slush 2026

Sullivan & Worcester will once again participate in Slush 2026, taking place November 18-19 in Helsinki, Finland. One of the world's leading startup events, Slush brings together entrepreneurs and investors from around the globe, offering a unique opportunity to connect with the Nordic technology community and explore new business opportunities. Representing the firm's Emerging Companies & Venture Capital, Intellectual Property and Mergers & Acquisitions practices, Sullivan's team will include Scott Kaufman, Mike Palmisciano, Michael

Events
Looking ahead or back to basics? ECA reform priorities to remain competitive

Partner Mark Norris⁠ will participate in GTR Africa 2026 London, hosted by Global Trade Review (GTR) on November 12, the theme for which is “Charting Africa’s trade and export trajectory.” Mark will join the panel discussing “Looking ahead or back to basics? ECA reform priorities to remain competitive”, which will be moderated by Chris Mitman at Acre Impact Capital and include Ram Shalita at Bluebird Finance & Projects and Anders Vium

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