Kenneth Zuckerbrot represents public and private corporations and inbound and outbound investment companies in tax and real estate matters and has wide-ranging experience in debt restructurings. Ken's experience in both International taxation and REIT work is combined in the tax efficient acquisition structures of foreign real estate by U.S. REITs.
Areas of Concentration
· Bankruptcy tax planning
· International taxation
· Debt restructuring
· Real estate
· REIT taxation
· Organization, qualification and operation of REITs
Professional & Community Involvement
· Member, American Bar Association, Section of Taxation
Awards & Recognition
· Listed, Chambers USA Guide, 2012-2013
· Listed, Super Lawyers magazine, New York Super Lawyers, 2006, 2008-2013
· Member, Winning Team, Global M&A Network's 2012 Turnaround Atlas Award for "Turnaround of the Year - Upper Mid Markets" for the pre-packaged Chapter 11 restructuring and recapitalization of Satélites Mexicanos S.A. de C.V.
· Member, Winning Team, Latin Lawyer's "Deal of the Year - Restructuring" Award, 2012
· Rated, AV Preeminent® 5.0 out of 5
· Involved in the restructuring of the debt on 400 properties with a total mortgage debt in excess of $1 billion.
· Structured the purchase of over 60 parcels of real estate valued over $400 million in the United Kingdom for clients and their institutional partners.
· Resolved the business and accounting differences involving a closely held real estate company and three generations of trust beneficiaries. The total amount of the dispute exceeded $200 million.
· Advised bank holding company with $900 million of net operating loss. Helped secure contested income tax refund in litigation with FDIC.
· Structured the transfer of a $200 million net operating loss to a creditor in bankruptcy.
· Designed and implemented an alternative structure to the real estate synthetic lease.
· Designed structure to release certain tax reserves from corporate balance sheets.
· Transferred an internet operating company offshore; oversaw all transfer pricing and corporate governance issues.
Publications & Presentations
Articles, Lectures & Publications
· Co-author, "The Stop Tax Haven Abuse Act: Indications of Future Changes In International Tax Landscape." Practical U.S./International Tax Strategies, Vol. 13, No. 4, February 28, 2009
· Co-author, "So Long GAAP, Hello IFRS (International Financial Reporting System)," Practical U.S. International Tax Strategies, January 2008
· Co-author, "The New Mexican Flat Rate Business Contribution and its Creditability for U.S. Federal Income Tax Purposes," Practical Mexican Tax Strategies, September/October 2007
· Co-author, "Renegotiation or Modification of Debt Instruments and FIN 48," Greenberg Traurig Alert, May 2007
· Co-author, "Corporate Tax Shelters - Chapter 3: The Treasury Aims at Opinion Writers,"Corporate Tax and Business Planning Review, Vol. 42, No. 7, Tax Management Inc., March 26, 2001
· Author, "Getting Into and Out of Debt with the IRS," Bottom Line Personal, Vol. 3, No. 22; "Good Opinions," Financial Planning, March 1986
· Presenter, "Four Scenarios for Inbound Investment in the United States," Premier International, May 18, 2013