June 15, 2026
–Press Release
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Sarah Wellings was interviewed for a video segment titled "Sullivan & Worcester Partner Sees TRS Structure as Simpler, More Flexible Alternative for REITs," published by Nareit on April 27, 2026. The conversation was recorded at Nareit’s REITwise: 2026 Educational Conference in Hollywood, Florida, held March 24-26.
In the interview, Sarah outlined key operational risks REITs face with taxable REIT subsidiaries (TRSs), emphasizing that using TRSs can simplify compliance compared to relying on independent contractors for non-customary services and can help mitigate tax exposure on asset transfers. She also highlighted the importance of robust transfer pricing documentation and noted that while technology is improving compliance, implementation and user adoption challenges persist.
Sarah Wellings was interviewed for a video segment titled "Sullivan & Worcester Partner Sees TRS Structure as Simpler, More Flexible Alternative for REITs," published by Nareit on April 27, 2026. The conversation was recorded at Nareit’s REITwise: 2026 Educational Conference in Hollywood, Florida, held March 24-26.
In the interview, Sarah outlined key operational risks REITs face with taxable REIT subsidiaries (TRSs), emphasizing that using TRSs can simplify compliance compared to relying on independent contractors for non-customary services and can help mitigate tax exposure on asset transfers. She also highlighted the importance of robust transfer pricing documentation and noted that while technology is improving compliance, implementation and user adoption challenges persist.
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 Wellings was interviewed for a video segment titled "Sullivan & Worcester Partner Sees TRS Structure as Simpler, More Flexible Alternative for REITs," published by Nareit on April 27, 2026. The conversation was recorded at Nareit’s REITwise: 2026 Educational Conference in Hollywood, Florida, held March 24-26.
In the interview, Sarah outlined key operational risks REITs face with taxable REIT subsidiaries (TRSs), emphasizing that using TRSs can simplify compliance compared to relying on independent contractors for non-customary services and can help mitigate tax exposure on asset transfers. She also highlighted the importance of robust transfer pricing documentation and noted that while technology is improving compliance, implementation and user adoption challenges persist.
Simon Cook, in his role as ITFA's Head of Education, will jointly moderate a Q&A on “The next generation: Three emerging leaders, three ideas”, together with Charlie O'Mulloy, chair of ITFA’s Emerging Leader Committee and Associate Banker at EBRD, at ITFA’s 52nd Annual International Trade and Forfaiting Conference in Split, Croatia on September 9. The Q&A will follow the presentations made by the finalists of the 2026 ITFA Emerging Leader
Sullivan partner Tehila Levi Lati will speak at a webinar held in collaboration with Amazon and Digate titled "Going Live in China" on September 8, 2026. Designed for decision-makers and technical leaders navigating regional expansion, the program will explore key technical, legal and operational considerations for launching in China, including cloud infrastructure, local licensing, data privacy and corporate risk management. During the webinar, Tehila will leverage her deep experience leading Sullivan's China and
On July 29, 2026, the Securities and Exchange Commission (the "SEC") notified Nasdaq that it had received notices of intention to petition for review of the SEC's July 22, 2026 order approving Nasdaq's proposed rule change requiring listed companies to maintain a minimum Market Value of Listed Securities ("MVLS") of $5 million. Pursuant to Rule 431(e) of the SEC's Rules of Practice, the July 22, 2026 approval order has been
(London and New York) – Sullivan has advised BAFT (the Bankers Association for Finance & Trade) and ITFA (the International Trade and Forfaiting Association) on the publication of the two Capital Requirements Regulation (CRR) legal opinions covering the 2008 English law Master Participation Agreement (MPA). The newly released opinions comprise the EU CRR opinion on English law MPA 2008 and the UK CRR opinion on English law MPA 2008. They are intended
Geoffrey Wynne will participate in a panel discussion at ITFA's 52nd Annual International Trade and Forfaiting Conference alongside Ailsa McNeil, Director at Texel, and Hernan Mayol, Board Member and Representative of ITFA Americas and Chair of ITFA’s Latin America Regional Committee (LARC). The session, titled “Financing the future: From defence to critical raw materials,” will be moderated by Clarissa Dann, Editorial Director at Deutsche Bank AG. The session will explore how trade
Sullivan & Worcester represented long-term client Olibra LLC, the owner of the Bond smart-home connectivity platform, in its acquisition by Somfy Group, a global leader in the motorization and automation of openings and closures for homes and buildings. Bond will continue to operate independently under its existing leadership team while benefiting from Somfy's global resources, industry expertise and long-term investment. The transaction brings together Somfy's expertise in motorization and automation with
Douglas S. Stransky, partner and leader of the Tax Practice Group, has published a new post on the LexisNexis blog examining a recurring problem in cross-border acquisitions: entity classification errors discovered in tax due diligence. Using a hypothetical fact pattern in which a target’s foreign subsidiary never filed its check-the-box election, the post explains why classification mistakes persist, how a missing Form 5471 can leave the assessment statute open indefinitely under
Since the publication of this Client Alert on July 30, 2026, several significant developments have affected the implementation of NYC’s Non-Primary Residence Surcharge (the “Pied-à-Terre Tax”), including the NYC Department of Finance (“NYC DOF”) extending the deadline for property owners to submit exemption applications to September 18, 2026. On August 7, 2026, three NYC homeowners filed a lawsuit challenging the City’s implementation of the surcharge, including the City’s process of identifying
New York City Department of Finance (“NYC DOF”) recently began notifying property owners by mail that they may be subject to the City’s new Non-Primary Residence Surcharge, which will be imposed annually on certain high-value residential properties that are not used as primary residences.[i] Although the surcharge is commonly referred to as the “Pied-à-Terre Tax,” it applies to a broader range of non-primary residences. Receipt of a notice does not necessarily
Sullivan & Worcester represented Longfellow Investment Management Co., LLC (LIM), a Boston-based investment management firm, in establishing a global distribution partnership with subsidiaries of iM Global Partner, a global asset management firm, and the sale of a minority, non-controlling equity interest. Through the partnership, LIM is expected to expand its global distribution footprint and access additional investment product structures, including mutual funds, UCITS and ETFs, while maintaining its majority employee
Simon Cook, in his role as ITFA's Head of Education, will jointly moderate a Q&A on “The next generation: Three emerging leaders, three ideas”, together with Charlie O'Mulloy, chair of ITFA’s Emerging Leader Committee and Associate Banker at EBRD, at ITFA’s 52nd Annual International Trade and Forfaiting Conference in Split, Croatia on September 9. The Q&A will follow the presentations made by the finalists of the 2026 ITFA Emerging Leader
Sullivan partner Tehila Levi Lati will speak at a webinar held in collaboration with Amazon and Digate titled "Going Live in China" on September 8, 2026. Designed for decision-makers and technical leaders navigating regional expansion, the program will explore key technical, legal and operational considerations for launching in China, including cloud infrastructure, local licensing, data privacy and corporate risk management. During the webinar, Tehila will leverage her deep experience leading Sullivan's China and
On July 29, 2026, the Securities and Exchange Commission (the "SEC") notified Nasdaq that it had received notices of intention to petition for review of the SEC's July 22, 2026 order approving Nasdaq's proposed rule change requiring listed companies to maintain a minimum Market Value of Listed Securities ("MVLS") of $5 million. Pursuant to Rule 431(e) of the SEC's Rules of Practice, the July 22, 2026 approval order has been
(London and New York) – Sullivan has advised BAFT (the Bankers Association for Finance & Trade) and ITFA (the International Trade and Forfaiting Association) on the publication of the two Capital Requirements Regulation (CRR) legal opinions covering the 2008 English law Master Participation Agreement (MPA). The newly released opinions comprise the EU CRR opinion on English law MPA 2008 and the UK CRR opinion on English law MPA 2008. They are intended
Geoffrey Wynne will participate in a panel discussion at ITFA's 52nd Annual International Trade and Forfaiting Conference alongside Ailsa McNeil, Director at Texel, and Hernan Mayol, Board Member and Representative of ITFA Americas and Chair of ITFA’s Latin America Regional Committee (LARC). The session, titled “Financing the future: From defence to critical raw materials,” will be moderated by Clarissa Dann, Editorial Director at Deutsche Bank AG. The session will explore how trade
Sullivan & Worcester represented long-term client Olibra LLC, the owner of the Bond smart-home connectivity platform, in its acquisition by Somfy Group, a global leader in the motorization and automation of openings and closures for homes and buildings. Bond will continue to operate independently under its existing leadership team while benefiting from Somfy's global resources, industry expertise and long-term investment. The transaction brings together Somfy's expertise in motorization and automation with
