Bio

Michael J. Fellerman’s practice concentrates on the taxation of business transactions, including those involving real estate and partnerships. He advises domestic and international clients on all tax aspects of business transactions and tax planning, including those involving sophisticated partnership agreements. He also structures and advises clients on like-kind exchanges of real property. Mr. Fellerman regularly structures transactions and entities (e.g., C corporations, S corporations, partnerships, limited partnerships and limited liability companies) to achieve tax and economic advantages that are consistent with the goals of clients. Mr. Fellerman forms, expands and works with numerous tax-exempt entities. He advises on numerous matters that may impact on the entities' tax-exempt status, as well as to avoid or minimize exposures to unrelated business taxable income (UBTI) and various special taxes and penalties. Additionally, Mr. Fellerman represents U.S. business entities and individuals seeking to invest or conduct business abroad and foreign business entities and individuals seeking to invest or conduct business in the U.S. In connection with such representation, Mr. Fellerman frequently works with U.S. foreign taxation rules, including the various Subpart F rules (CFC and PFIC rules), treaty analysis, and the Foreign Investment in Real Property Tax Act (FIRPTA). He also advises clients with respect to U.S. withholding matters and tax reporting issues. Further, Mr. Fellerman advises hedge funds in their formation, including international fund structures, such as Master Feeder Funds, and advises them on the numerous tax matters that arise.