Michael Torhan is a Tax Partner in the Real Estate Services Group. He provides tax compliance and consulting services to clients in the real estate, hospitality, and financial services sectors. Michael has extensive tax experience in a wide range of real estate transactions, including joint ventures; formation and operation of private equity funds; real estate acquisitions, dispositions, financings, and refinancings; Section 1031 like-kind exchange transactions; and Section 467 lease agreements.
Michael has substantial tax experience with the partnership entity structure, including mergers and acquisitions, joint ventures, disguised sale transactions, income allocations, partner liability allocations, and review and analysis of operating agreements. He has developed complex waterfall and targeted capital allocation models to track and analyze distributions and income allocations. Michael has also been involved with tax compliance and transactional consulting for Real Estate Investment Trusts (“REITs”) including their formation, qualification, operation, and dissolution. He has provided tax advisory services for the structuring of real estate private equity funds in combination with REITs to maximize value for foreign and tax-exempt investors.
Additionally, Michael has handled tax controversy matters, including representation of taxpayers before federal, state, and local taxing authorities; settlement negotiations; and protest consultation with the IRS Appeals Office.
Michael is actively involved with professional organizations. He also frequently writes for publication on topics such as the issuance of new treasury regulations and tax considerations for real estate private equity funds and REITs.