Christopher Mangin, Jr.

Co-led ABA Section of Taxation’s comment letter on Treasury and IRS’s proposed regulations under Sections 897 and 892 regarding issues affecting foreign investment in U.S. real estate

Bluerock Residential Growth REIT as special tax counsel in its $3.6 billion acquisition by affiliates of Blackstone Real Estate and the spin-off its single-family rental business into Bluerock Homes Trust, a newly formed REIT

DigitalBridge in its acquisition of a controlling stake in Vertical Bridge Holdings, the largest private owner and operator of wireless communications infrastructure in the U.S.

WPT Industrial Real Estate Investment Trust in its $3.1 billion sale to Blackstone Real Estate Income Trust, Inc.

Data Foundry, Inc., a carrier-neutral colocation and data center provider, in its $420 million sale to Switch, Inc.

Jera Asset Management and Setzer Properties in formation of a joint venture with the Australian Superannuation Pension Fund, including the roll-up of a seed portfolio of net leased transportation terminal and logistics properties

Alpine Income Property Trust, Inc. in its $143 million initial public offering of common stock

CTO Realty Growth, Inc. in its conversion to a REIT

NorthStar Realty Europe Corp. as special tax counsel in its merger with Core Paneuro 2019 13 Sarl

The Special Committee of the Board of Directors of Owens Realty Mortgage, a specialty finance REIT, in its $200 million merger with Ready Capital Corporation, a real estate finance company

Oncor Electric Delivery Company in its $2.2 billion acquisition of InfraREIT

CYS Investments, an agency mortgage REIT, in its $1.475 billion merger with Two Harbors Investment Corp., a leading hybrid mortgage REIT

TPG RE Finance Trust, Inc. in its $233 million initial public offering and multiple follow-on offerings

TPG RE Finance Trust, Inc., as special tax counsel, in its $932.4 million collateralized loan obligation (CLO)

NorthStar Realty Finance in its approximately $16 billion combination with NorthStar Asset Management Group and Colony Capital in an all-stock merger of equals

Global Medical REIT Inc. in its $150 million initial public offering of common stock and all of its subsequent capital markets transactions including five follow-on underwritten public offerings with an approximate transactional value of $343 million; ATM offerings; and its $77 million public offering of Series A cumulative redeemable preferred stock

Issuers and underwriters in public and private equity and debt offerings by REITs

Targets and acquirors in tax-deferred and taxable mergers and acquisitions, reorganizations, restructurings, and dispositions, including tax-free spin-offs under Section 355 of the Internal Revenue Code

REITs, including hotel REITs, equity REITs, healthcare REITs, commercial mortgage REITs, residential mortgage REITs, and hybrid REITs, on investment structuring, including joint ventures with operators, taxable REIT subsidiary (TRS) structures, investments in funds, mezzanine loans, and distressed debt

Buyers and sellers on the tax-efficient purchase, sale, and recapitalization of real estate and real estate-owning entities

Tax planning on the formation of REITs and rollup transactions involving REITs and umbrella partnership real estate investment trusts (UPREITs) as well as DownREIT structuring 

Formation and restructuring of real estate joint ventures using partnerships and limited liability companies

Clients in connection with private letter rulings (PLRs) submitted to the Internal Revenue Service

Matters arising under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA)