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, Johanna Colpritt and Nathan Kosik-Desmond
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
Douglas S. Stransky, partner and leader of the Tax Practice Group, has published the third post in his series for the LexisNexis blog, examining what happens when the most common structuring sequence in S corporation M&A runs into a target’s own election history. The post follows a hypothetical sale of a U.S. manufacturer to a foreign strategic buyer, where a pre-closing F reorganization under Rev. Rul. 2008-18 is the standard answer:
On September 11, 2026, the Securities and Exchange Commission (the “SEC”) granted petitions seeking review of the July 22, 2026 delegated approval of Nasdaq’s proposed $5 million Market Value of Listed Securities (“MVLS”) continued listing requirement. The SEC also confirmed that the approval order will remain stayed pending further order of the Commission. Accordingly, the new MVLS requirement is not currently in effect. If ultimately implemented, the rule would permit Nasdaq
Sullivan & Worcester’s recently acquired award-winning European Growth Capital Team, led by James Shaw and Ben Williams, advised ETF Partners (Lead) and A&G in connection with their continued support and investment in Open Cosmos, a U.K.-headquartered satellite technology company, as part of the company's €300 million funding round announced on September 14, 2026. The financing was backed primarily by European investors and represents one of the most significant recent investments in Europe's growing
Karen Kepler will moderate a panel discussion titled “From Subsidized to Missing Middle: Developing for Affordability” at Bisnow’s Multifamily Annual Conference (BMAC) New England, taking place September 24 at Artists For Humanity in Boston. The panel will examine the financing tools and subsidy structures available to affordable housing developers, the gaps that remain in the capital stack and how shifting development economics are prompting cities, developers and nonprofits to rethink how
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
Gregory Sampson was quoted in the Bisnow article, “Healey's New Data Center Rules Make Massachusetts A Tough Sell For Developers,” discussing Massachusetts Governor Maura Healey's executive order establishing new requirements for large-scale data center development in the Commonwealth. The article examines how the order will affect proposed data center projects, including requirements related to local approval, community benefit agreements, power infrastructure and environmental impacts. As discussed by Greg, the order was the
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 & Worcester was pleased to sponsor the 2026 ITFA Emerging Leader Award, presented at the Gala Dinner during ITFA’s 52nd Annual International Trade and Forfaiting Conference in Split, Croatia. Following presentations by the three shortlisted candidates and a vote by delegates attending the conference, Harry Thursby-Pelham at HSBC was named the 2026 winner for his project, ‘Fluent in Finance’. Sullivan partner and head of the firm’s Trade & Export Finance
John Hunt will participate in a panel discussion titled "Regulatory Review & Potential Reforms" at Crane Data’s European Money Fund Symposium on September 25, 2026, in Paris, France. John will be joined by Dennis Gepp, Head of European Government Affairs at Federated Hermes. Recent and upcoming regulatory changes impacting European and UK money market funds will be explored. The European Money Fund Symposium offers "offshore" money fund portfolio managers, and money market investors,
On August 5, 2026, Article 28-F of the New York Public Health Law (the “Medical Aid in Dying Act” or the “Act”) became effective, creating a framework under which, in certain limited circumstances, terminally ill New York residents may request and self-administer medication intended to hasten death.[i] Although narrow in its scope, the Medical Aid in Dying Act serves as a reminder of the importance of advanced healthcare planning and clearly
Douglas S. Stransky, partner and leader of the Tax Practice Group, has published the third post in his series for the LexisNexis blog, examining what happens when the most common structuring sequence in S corporation M&A runs into a target’s own election history. The post follows a hypothetical sale of a U.S. manufacturer to a foreign strategic buyer, where a pre-closing F reorganization under Rev. Rul. 2008-18 is the standard answer:
On September 11, 2026, the Securities and Exchange Commission (the “SEC”) granted petitions seeking review of the July 22, 2026 delegated approval of Nasdaq’s proposed $5 million Market Value of Listed Securities (“MVLS”) continued listing requirement. The SEC also confirmed that the approval order will remain stayed pending further order of the Commission. Accordingly, the new MVLS requirement is not currently in effect. If ultimately implemented, the rule would permit Nasdaq
Sullivan & Worcester’s recently acquired award-winning European Growth Capital Team, led by James Shaw and Ben Williams, advised ETF Partners (Lead) and A&G in connection with their continued support and investment in Open Cosmos, a U.K.-headquartered satellite technology company, as part of the company's €300 million funding round announced on September 14, 2026. The financing was backed primarily by European investors and represents one of the most significant recent investments in Europe's growing
Karen Kepler will moderate a panel discussion titled “From Subsidized to Missing Middle: Developing for Affordability” at Bisnow’s Multifamily Annual Conference (BMAC) New England, taking place September 24 at Artists For Humanity in Boston. The panel will examine the financing tools and subsidy structures available to affordable housing developers, the gaps that remain in the capital stack and how shifting development economics are prompting cities, developers and nonprofits to rethink how
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
Gregory Sampson was quoted in the Bisnow article, “Healey's New Data Center Rules Make Massachusetts A Tough Sell For Developers,” discussing Massachusetts Governor Maura Healey's executive order establishing new requirements for large-scale data center development in the Commonwealth. The article examines how the order will affect proposed data center projects, including requirements related to local approval, community benefit agreements, power infrastructure and environmental impacts. As discussed by Greg, the order was the