Service Areas
- Business
- Tax: Federal
- Corporate, Securities + Commercial Transactions
- Governments + Nonprofits
- Tax: Federal
Education
- Wayne State University Law School, J.D., LL.M
- Michigan State University, B.A.
Bar Admissions
- Michigan
Ryan Riehl focuses his practice on federal and state of Michigan tax issues. He specializes in partnership taxation, like-kind exchanges and other real estate tax matters, corporate acquisitions, dispositions and reorganizations, research and development tax credits and international tax planning for both U.S. companies conducting business abroad and non-residents with U.S. business activities.
The following recent transactions evidence Ryan’s experience advising clients in various state and federal tax issues:
Issued tax opinions used in private placement memorandums in connection with the tax treatment of oil and gas royalty interests under like-kind exchange provisions of the Internal Revenue Code.
Developed tax structure for the redemptions/sales of partners’ in interests in closely held general partnerships and limited liability companies engaged in farming, medical services and other business activities.
Representative Matters
- Cross Border Operations Tax Matters
Restructured U.S. and Canadian businesses with cross-border operations to avoid adverse tax consequences brought about by recent changes to the U.S.-Canada Tax Treaty.
- European Automotive Supplier Tax Planning
Developed and coordinated tax planning for $560,000,000 stock and asset acquisition of companies in the U.S. and 12 foreign countries by a European automotive supplier.
- Financial Institution Exchange Transactions
Represented publicly traded bank’s like-kind exchange services group in connection with more than 60 like-kind exchange transactions ranging in value from $800,000 to $300,000,000, including forward and reverse like-kind exchanges, build-to-suit exchanges, related-party exchanges, exchanges of tenancy-in-common interest as well as oil, gas and other mineral working and non-working (royalty) interests.
- OEM Supplier Tax Credit Claim
Assisted in the preparation of $6,000,000 R&D tax credit claim for large OEM supplier and successfully defended substantially all of such claim on audit.
- Oil and Gas Royalty Investment Company Tax Opinions
Issued tax opinions used in private placement memorandums in connection with the tax treatment of oil and gas royalty interests under like-kind exchange provisions of the Internal Revenue Code.
- Partnership/Limited Liability Company Tax Planning
Developed tax structure for the redemptions/sales of partners’ in interests in closely held general partnerships and limited liability companies engaged in farming, medical services and other business activities.
Honors + Awards
- Wayne State University Law School, summa cum laude; Order of the Coif; Law Review; Golden Key Award, 2001-02, 2002-03; Faculty Awards for Torts, Taxation and Constitutional Law Raymond Krell, Charles Hammond Memorial; Francis Driker and Ferne Walter Dean's Scholarships
- Michigan State University, with high honors
Publications
"Charitable Contributions," Lorman Education Services, Tax-Exempt Organizations in Michigan Seminar, February, 2006
"Double Talking the Right to Counsel" (Pending publications in Wayne Law Review, volume 50:1)
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