September 16, 2026
–Blog Post
Same Business, New Number: Rev. Rul. 2008-18, the 60-Month Rule, and the Price of the Fix
LexisNexis

Sullivan represented Horizon Beverage Group Inc., one of New England’s premier alcohol distributors, in its sale to Southern Glazer’s Wine & Spirits, the world’s preeminent distributor of beverage alcohol. The acquisition marks an exciting expansion for Southern Glazer’s, adding Massachusetts and Rhode Island as the 46th and 47th markets in its U.S. footprint, alongside operations in Canada and the Caribbean.
“We are grateful to Horizon’s employees, customers, and partners for so many years of success, and this transition represents an even brighter future for all,” said Bob Epstein, CEO/President at Horizon. “We’re confident that Southern Glazer’s strength and scale will not only support a smooth integration, but also create new opportunities for growth and success.”
“We’re committed to maintaining the exceptional service that Horizon is known for while bringing the added benefits of being part of the Southern Glazer’s family,” added Jim Rubenstein, CEO/Treasurer at Horizon. “This partnership ensures stability and growth for all stakeholders and strengthens our ability to deliver value across the board.”
Lewis N. Segall, Charles E. Chambers Jr., Ida J. Vanto, Sharon G. Leifer, Steven M. Cunningham, Jr. and Christopher C. Curtis
Sullivan represented Wonder Media Network (WMN), a female-founded, audio-first creative studio based in New York City, in its sale to Acast, the world’s largest independent podcast company. "WMN’s mission is so tightly aligned with that of Acast - bringing important and changemaking stories to the world," said WMN CEO Jenny Kaplan. "Together, we will allow both creators and advertisers to reach new audiences, build successful businesses, and shape the future of audio."
Lewis N. Segall, Joel R. Carpenter, Amy E. Sheridan, Erika L. Todd and Johanna Colpritt
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
Sullivan acts as outside general counsel for Skillsright, Inc., a nonprofit coalition of the country’s top employers and their CEOs with a mission of driving a skills-first movement to unlock career opportunities for talent without four-year degrees, for a more equitable and inclusive future workforce. Sullivan handles a wide range of matters including obtaining the organization’s nonprofit (Internal Revenue Code Section 501(c)(3)) status, advising on a variety of legal issues associated with the organization’s work, negotiating intellectual property rights, drafting employment offers and dealing with related employment and benefits issues, overseeing all contracting issues and advising on corporate governance.
Kimberly Herman, David A. Guadagnoli, Judith G.H. Edington, Erika L. Todd and Michael S. Palmisciano
Sullivan represented Admiral Metals who was acquired by Reliance Steel & Aluminium Co. (NYSE: RS). “Admiral Metals has built a strong reputation in the metals industry for providing specialty products, high levels of customer service and next-day delivery,” commented Jim Hoffman, Chief Executive Officer of Reliance. “We believe this acquisition will enable Admiral Metals to leverage Reliance’s scale in order to capitalize on further growth opportunities while maintaining its strong brand recognition. We are excited to welcome Admiral Metals to the Reliance Family of Companies, our 70th acquisition since our 1994 IPO.”
Lewis N. Segall, Victor N. Baltera and Sharon G. Leifer
Sullivan represented Masy Systems Inc. ("Masy" or "Masy BioServices"), a preferred provider of cGMP Biostorage and pharma support services, in the sale of its Masy to Alcami Corporation, a leading pharmaceutical and biotech contract development and manufacturing organization (CDMO).
Lewis N. Segall and Steven M. Cunningham, Jr.
In November 2021, Sullivan together with its clients Merger & Acquisition Services, Inc., and International Transportation Marine Office, LLC (ITMA) received the Cross-Border Deal of the Year ($50 to $100 million) Award, at the 20th Annual M&A Advisor Awards in New York City. The award was given for the sale of ITMA to MS Amlin Underwriting Limited, a UK company. Don Kaitz retained his role as chairman of Arizona-headquartered ITMA, and the business continued to be led by Eric Kaitz, Chief Executive Officer. Earlier in 2021, Douglas Stransky and Michael Student, along with Merger & Acquisition Services Inc., advised ITMA and the Kaitzes.
Partner and head of Sullivan's International Tax Group, Douglas Stransky, commented, "We are thrilled to receive this honor and be together in-person with our clients and friends, Merger & Acquisition Services, Inc. and Don and Eric Kaitz, and proud to have collaborated with them on this sale."
Douglas S. Stransky and Michael J. Student
The Massachusetts Appeals Court recently issued a useful reminder that aggressive discovery positions risk negative consequences far beyond facing motions to compel. In Old Ironsides Energy LLC v. Marsh & McLennan Agency LLC[1], the court affirmed summary judgment against a plaintiff seeking approximately $20 million in damages after concluding that the plaintiff lacked admissible expert testimony necessary to prove its claimed damages. The $20 million kicker? Expert testimony would have been admissible
On September 16, 2026, the Securities and Exchange Commission (SEC) issued two proposals that, if adopted, would represent significant changes to the federal proxy rules for U.S. public companies. The first proposal would eliminate Rule 14a-8 under the Securities Exchange Act of 1934 (Exchange Act). Rule 14a-8 currently requires companies to include qualifying shareholder proposals in their proxy materials and has been part of the federal proxy rules for more than
Molly Depew will co-present “Estate Tax and the Gross Estate,” a webinar hosted by the American Bar Association’s Section of Real Property, Trust and Estate Law, on October 8, alongside Preston Channing Demouchet. The first session in the ABA’s “Basics of Estate, Gift, and Generation-Skipping Transfer Tax” webinar series will review the application of the federal estate tax. Topics will include the tax rate and unified credit for residents and non-residents,
Alexandra (Ali) Wannop, counsel in Sullivan’s Real Estate Practice Group, was featured in the New England Real Estate Journal’s “2026 Women in CRE: CREW Boston Member Spotlight.” In the feature, Ali reflects on how advice from an early mentor shaped her approach to resolving complex title issues. She emphasizes the value of looking beyond conventional interpretations and questioning assumptions to find solutions in challenging transactions. “I’ve learned that what looks like a dead
On Friday, September 18, 2026, the Massachusetts Supreme Judicial Court (the “SJC”) affirmed the dismissal of the Town of Marshfield’s challenge to the MBTA Communities Act (the “Act” or “Section 3A”).[1] The decision confirms that covered municipalities must adopt and maintain zoning that permits multifamily housing as of right in at least one district. It also rejects Marshfield’s four principal theories for avoiding that obligation, which are explored in more
Partner Geoffrey Wynne will participate in The Trade Finance Compliance Conference hosted by leading global consultancy HKA and IIBLP (the Institute of International Banking Law & Practice) in London on October 6, the theme of which is “Inside Real-World Trade Finance Compliance Decision-Making.” Geoff will join the panel discussing “Fraud, TBML (Trade-Based Money Laundering) and credit risk - one fact pattern, three silos” which will be moderated by Lorna Strong (Associate
First, a crucial clarification. While The Princess Bride (the wonderful movie) has the frame narrative of a grandfather who reads the book to his grandson, The Princess Bride (the wonderful book) has the frame narrative of a man whose father read it to him, and who wants to share it with his own son. The book is out of print, and the man sends his lawyer to a used bookstore
Sullivan partners Carole Bass and Douglas Schneidman have been recognized in the 2026 edition of Doyle’s Guide among New York City’s Leading Wealth, Estates & Succession Planning Lawyers. Carole, who leads the firm’s Private Clients/Trusts & Estates practice, was named a leading lawyer, and Doug was named a recommended lawyer. Carole advises high-net-worth individuals, multigenerational families, family offices and fiduciaries on estate, wealth transfer and trust planning. She designs sophisticated, tax-efficient
Richard Jones will speak on a panel discussion titled "Practitioner Feedback" on October 8, 2026, at the 46th Annual National Conference of State Tax Judges at the Lincoln Institute of Land Policy in Cambridge, Massachusetts. The Conference meets annually to review recent state tax decisions, consider methods of dealing with complex tax and valuation disputes, and share experiences in case management. Rich's practitioner-focused panel will explore practical strategies and best practices
The Massachusetts Appeals Court recently issued a useful reminder that aggressive discovery positions risk negative consequences far beyond facing motions to compel. In Old Ironsides Energy LLC v. Marsh & McLennan Agency LLC[1], the court affirmed summary judgment against a plaintiff seeking approximately $20 million in damages after concluding that the plaintiff lacked admissible expert testimony necessary to prove its claimed damages. The $20 million kicker? Expert testimony would have been admissible
On September 16, 2026, the Securities and Exchange Commission (SEC) issued two proposals that, if adopted, would represent significant changes to the federal proxy rules for U.S. public companies. The first proposal would eliminate Rule 14a-8 under the Securities Exchange Act of 1934 (Exchange Act). Rule 14a-8 currently requires companies to include qualifying shareholder proposals in their proxy materials and has been part of the federal proxy rules for more than
Molly Depew will co-present “Estate Tax and the Gross Estate,” a webinar hosted by the American Bar Association’s Section of Real Property, Trust and Estate Law, on October 8, alongside Preston Channing Demouchet. The first session in the ABA’s “Basics of Estate, Gift, and Generation-Skipping Transfer Tax” webinar series will review the application of the federal estate tax. Topics will include the tax rate and unified credit for residents and non-residents,
Alexandra (Ali) Wannop, counsel in Sullivan’s Real Estate Practice Group, was featured in the New England Real Estate Journal’s “2026 Women in CRE: CREW Boston Member Spotlight.” In the feature, Ali reflects on how advice from an early mentor shaped her approach to resolving complex title issues. She emphasizes the value of looking beyond conventional interpretations and questioning assumptions to find solutions in challenging transactions. “I’ve learned that what looks like a dead
On Friday, September 18, 2026, the Massachusetts Supreme Judicial Court (the “SJC”) affirmed the dismissal of the Town of Marshfield’s challenge to the MBTA Communities Act (the “Act” or “Section 3A”).[1] The decision confirms that covered municipalities must adopt and maintain zoning that permits multifamily housing as of right in at least one district. It also rejects Marshfield’s four principal theories for avoiding that obligation, which are explored in more