Overview Steven Schneider is a Director in our Tax group. He has significant experience in a wide variety of domestic and international transactions with particular experience in the taxation of pass-through entities such as partnerships, S corporations and REITs. His work crosses several industries including real estate, technology, energy and the financial sector. Steve also brings significant knowledge through his prior experience in the IRS National Office and in the national office of a Big-Four accounting firm. Steve is also an Adjunct Professor at the Georgetown University Law Center LL.M. program, teaching Drafting Partnership and LLC Agreements. Steve authors a blog covering tax-related topics called TaxLawRoundup. In the blog, he provides succinct and timely summaries of important U.S. tax guidance affecting your business. Representative Experience · Representation of Federal Realty Investment Trust in connection with the formation of a joint venture and acquisition of a controlling interest in Montrose Crossing, a 357,000 square foot existing shopping center with an adjacent developable parcel in Maryland. · Representation of large global real estate funds on federal income tax matters relating to international and domestic real estate acquisitions and dispositions. · Representation of Federal Realty Investment Trust in connection with multiple separate joint venture arrangements and the acquisition of a controlling interest in Plaza El Segundo in California. · Significant subject matter expertise and experience including partnerships, S corporations, REITs, equity-based compensation, TEFRA partnership audits and tax shelter rules. · Successful representation of clients in significant federal tax controversy matters, including IRS Audit and Appeals. · Representation of large multi-family real estate clients on tax structuring and documentation. · Due diligence experience in partnership and corporate acquisitions involving dollar values ranging from multi-million to multi-billion. · Works with clients regarding "Green" aspects of taxation, with a focus on real estate. Professional and Community Involvement · American Bar Association (Tax Section), Immediate Past Chair, Partnerships and LLCs Press Releases July 2011, Goulston & Storrs Launches Tax Blog March 2010, Goulston & Storrs Attorney, Steve Schneider, Speaks at International Council of Shopping Centers December 2008, A Green Goulston & Storrs Client Advisories July 2011, Overview of Green Building Federal Tax Incentives February 2011, President Obama Proposes New Tax Credit for Energy Efficient Building Improvements August 2010, A Real Estate Developer's Guide to Carried Interest Legislation June 2010, House-Passed Carried Interest Legislation: Impact On Real Estate Partnerships - A Developer's Perspective March 2010, Newly Ordered Greenhouse Gas Reductions at Federal Facilities Create Market Opportunities February 2010, Tax Pitfalls for Purchasers of Distressed Debt December 2009, Today's Distressed World: Tax Traps and Planning Opportunities October 2009, Green Building Incentives in Maryland, Virginia and the District of Columbia September 2009, Extension of Foreign Bank Account Reporting Amnesty Deadline September 2009, IRS Guidance Creates More Flexibility For Securitized Debt Modifications September 2009, 12-Month Extension for Disbursement of Section 1602 Funds to certain Low Income Housing Tax Credit ("LIHTC") Projects August 2009, Treasury Starts Accepting Applications for Green Grants January 2009, Public Incentives for Large-Scale Sustainable Development August 2008, New Housing Bill Includes Many Favorable REIT Provisions. Blogs 01.30.12, Second Circuit Again Concludes Preferred Investor Was Not A Partner 01.25.12, Proposed Regulations Issued for DC's New Combined Reporting Rules 01.10.12, IRS Announces Third Late FBAR Amnesty Program 12.28.11, 10th Circuit Affirms Taxability of Variable Prepaid Forward Contracts 12.14.11, New Regulations On Foreign Financial Account Reporting 11.28.11, IRS Revamps Definition of "Limited Partner" for Section 469 Passive Activity Loss Rules 11.21.11, Super Committee Fails to Reach Budget Agreement 11.15.11, Final Regulations Address Partnership Debt-For-Equity Transactions 10.24.11, First Circuit Applies 40% Valuation Penalty On Son of BOSS Transaction 10.24.11, IRS Proposes Revocation of Partnership De Minimis Rule 10.07.11, Sen. Reid Proposes 5.6% Millionaire Surtax 10.05.11, IRS Has Three New Wins On Tax Shelter Cases 09.23.11, Proposed FIRPTA Legislation For Foreign Investors in U.S. Real Estate 09.20.11, Obama Explains How To Pay For The American Jobs Act 09.14.11, IRS Extends Deadlines for 2010 Estates 09.13.11, American Jobs Act - Carried Interest and Itemized Deduction Limitations 09.12.11, President Introduces American Jobs Act 09.09.11, Senate Passes Tax Patent Ban - President Expected to Sign 09.07.11, IRS Reproposes Regulations on Trusts and Estates and 2-Percent Itemized Deduction Floor 09.07.11, JCT Publishes Cross Border Taxation Summary 09.02.11, Final Regulations Address Reportable Transaction Penalties 09.02.11, IRS-Treasury 2011-2012 Business Plan Released 09.02.11, Tax Court Slams "DAD" Loss Importation Shelter 08.31.11, IRS Describes Check-The-Box Conversion of Insolvent Corporation To A Partnership 08.31.11, JCT Publishes Tax Reports On-Line Dating Back to 1926 08.29.11, FBAR Voluntary Disclosure - IRS Provides Short-term Extension to September 9 08.09.11, IRS Reminds Taxpayers of Aug. 31 Deadline for FBAR Voluntary Disclosure 08.08.11, IRS Guidance on Carryover Basis Election for 2010 Decedent Estates 08.03.11, Debt Ceiling Raised - Details to be Determined 08.03.11, Legislation Introduced to Address Sales Tax on Internet Sales 07.20.11, Gang of Six Outlines Deficit Reduction Plan 07.20.11, IRS Revises FAQs on Schedule UTP - Reporting Uncertain Tax Positions 07.18.11, New IRS Guidance to Field on Applying Economic Substance Doctrine 07.18.11, New Phased Implementation of Certain FATCA Requirements 07.18.11, Regulations Address Foreign Tax Credit Generator Transactions 07.08.11, Budget Negotiations Take Aim at "Tax Loopholes" 07.07.11, Court Rules Taxpayer Not a "Trader" - Losses Suspended 06.27.11, Final Regulations on Automatic Return Extensions 06.23.11, Broker Basis Reporting Guidance 06.23.11, D.C. Circuit Defers to IRS Regulations and Applies Six-Year Statute Of Limitations 06.20.11, Latest FBAR Guidance - Limited Filing Extension 06.15.11, JCT Report Provides Detail on Obama Tax Proposals 06.13.11, Timber Forest Carbon Emission Units are Good REIT Assets 06.06.11, New Market Tax Credit Changes Proposed to Encourage Investment in Operating Businesses 06.03.11, Latest FBAR Guidance - Extensions and Opting Out 06.01.11, 10th Circuit Defers to IRS Regulations and Applies Six-Year Statute Of Limitations 06.01.11, Final Circular 230 Regulations Create Registered Tax Return Preparer Category 06.01.11, IRS Updates Procedures for Determining Stock Basis 06.01.11, June 30 FBAR Deadline Extended for Certain Persons 05.27.11, Simplified Late Election Procedures For Passive Activity Loss Election 05.25.11, 5th Circuit Sides with Taxpayers against 6-Year Statute of Limitations 05.25.11, Final "Killer B" Regulations - Triangular Reorganizations With Foreign Corporations 05.09.11, PLR Disregards REIT's Share of REIT Loan to Partnership 05.05.11, District Court Finds Performance Fee Not Partnership Interest, No Capital Gain Treatment 05.05.11, Legislative Talk of Taxing Large Passthrough Entities 04.27.11, FAQs on Cost-Basis Reporting for Brokers 04.27.11, IRS Guidance on 100% Bonus Depreciation 04.27.11, IRS Guidance on FATCA for Foreign Financial Institutions 04.27.11, IRS Provides Capitalization Percentage Election for Acquisition "Success Fee" 04.27.11, Regulations Address How to Apply COD Exceptions for Disregarded Entities 04.27.11, Senate Passes Repeal of Expanded Form 1099 Reporting 04.27.11, Short-Term Capital Gain on Sale of State Tax Credits 04.27.11, Tax Court Reversed, State Tax Credits Transferred in Taxable Sale 04.27.11, Tax Court Treats Nominal Loan as Deemed Tax Sale 04.27.11, Tax Court Treats Service Partner Advances as Distributions 03.30.11, IRS Guidance on 100% Bonus Depreciation 03.30.11, Tax Court Finds Ordinary Bad Debt Loss on Loan Related to Venture Capital Business 03.30.11, Tax Court Reversed, State Tax Credits Transferred in Taxable Sale 02.15.11, President Releases 2012 Budget Proposals 02.09.11, Tax Court Denies Partnership Status to 100% Related Joint Venture 02.08.11, New Foreign Account FBAR Voluntary Disclosure Program 02.08.11, New Foreign Account FBAR Voluntary Disclosure Program 02.04.11, Obama Proposes Incentives for Energy Efficient Buildings - Paid for by Oil & Gas Industry 02.01.11, Obama Proposes Startup American Campaign to Promote Entrepreneurship and Innovation 01.27.11, 7th Circuit Sides with IRS on 6-Year Statute of Limitations 01.24.11, No Disguised Sale on Transfer of Underwater Property to Partnership 01.04.11, Court Respects Historic Rehab Credit Syndication Publications & Mentions November 2011, Supercommittee inaction could hurt D.C. leasing efforts November 2011, Treasury Finalizes Debt-for-Equity Regs With Implied Circular Flow of Cash July 2011, "Tax Regulations: For 2011-12 Plan, Attorneys Seek Guidance On Exempts, Partnerships, LLCs, Real Estate," Daily Tax Report June 2011, "Self-Help for Taking Bad Debt Deduction Will Be Addressed in Final Debt-for-Equity Regs, IRS Official Says," Tax Analysts June 2011, "IRS Very Close to Reproposing Rules on Noncomensatory Partnership Options," Daily Tax Report September 2010, "A Developer's Guide to Carried Interest Proposals," Washington Business Journal July 2010, "IRS Finalizes Partnership Allocation Antiabuse Rules for Contributed Property," Tax Analysts May 2010, "Buyout Firm Managers Face Tax Increase In Jobs Bill," Bloomberg Business Week December 21, 2009, "Partnership and LLC Agreements: Learning to Read and Write Again," Tax Notes, Special Report August 2009, Quoted "Practitioners Urge Clarification of Layering In Future Partnership Gain, Loss Guidance," BNA Daily Tax Update August 2009, Quoted, "IRS Includes Favorable Partial Election Option In Guidance on COD Income Deferral Election," BNA Daily Tax Update August 2009, "IRS Includes Favorable Partial Election Option In Guidance On COD Income Deferral Election" March 2009, "IRS Examining Whether Series LLCs Sub Accounts Are Separate Entities," BNA Daily Tax Report April 2007, Author, "FIN 48 for Tax Lawyers -- Accounting for Uncertainty in Income Taxes," 45 Tax Mgmt. Memorandum 139 Seminars & Events October 2011, U.S. Shopping Center Law Conference Workshop 21: Current Tax Issues for the Shopping Center Industry September 2011, Drafting Real Estate Partnership and LLC Agreements June 2011, Foreign Investment in US Real Estate June 2011, Looking Forward and Back: The Partnership and Real Estate Tax Year in Review with a Sneak Peak Ahead May 2011, Drafting Real Estate Partnership and LLC Agreements, ABA Section of Taxation April 2011, Tax Provisions of Partnerships and LLC Agreements: Learning to Read and Write Again January 2011, TEFRA and the TMP-- Too Much Power? January 2011, Basic Tax Considerations for Real Estate Developers November 2010, Real Estate Joint Ventures-- Structuring, Restructuring and Documenting September 2010, Key Tax Considerations In All Types of Ventures September 2010, Real Estate Joint Ventures and Funds Conference July 2010, Carried Interest Legislation Update July 2010, The Carried Interest Tax Increase & its Impact on Real Estate Partnerships June 2010, "Leveraging Federal Guidance and Rulings to Establish Material Participation" May 7, 2010, "Partnership Exit Strategies: You Don't Have to Go Home, But You Can't Stay Here" March 29, 2010, Real Estate Legislative Update March 29, 2010, Economic Subcommittee Meeting December 2009, Tax Issues Associated with Tax Exempt Entities and REITs as Owners of Real Estate September 2009, Whose Money Is It? Capital Shifts and Their Taxability March 2009, Recent Developments in Partnership Taxation |