Stefan helps clients acquiring or selling businesses or securities, financing businesses, or entering into financial instrument transactions. Tax services Stefan has provided includes structuring private equity and hedge fund acquisitions, investments, sales and restructurings, advising on limitations on the tax deductibility of interest, such as section 163(j) and AHYDO. He also has provided tax treatment of standard or customized financial instruments based on underlying assets such as commodities, cryptocurrency, debt, pharmaceutical products, partnership interests and stock and tax opinion for split up of REIT with assets of approximately $4 billion. In addition to, providing tax opinions for public company and private company merger/reorganization transactions.
Stefan serves clients through analysis of cancellation of debt income in bankruptcies and debt workouts, and with spin-off transaction and private letter ruling request advice. He also advises on debt financing, refinancing and equity recapitalization tax analysis and structuring, the application of the section 382 limitation to net operating losses, and exclusion of capital gain on stock from taxable income under section 1202. Stefan is equipped in tax cost classification and cost recovery in acquisitions, financings and bankruptcies and structuring for disposition of investments, subsidiaries and business lines.
Stefan’s transaction tax experience aids in driving client’s clear understanding of their tax positions with the goal of defining the best path forward.
Stefan has written many published articles on M&A tax, financial instruments tax and international tax topics. Away from work, he enjoys swimming and yoga. He is also passionate about music and has a collection of vinyl records that numbers in the thousands.