Ryan J. Riehl

Represented Second City Capital Partners II, LP, on the spin-out and "roll up" of more than 20 companies holding 16 office properties consisting of 1.85 million sq. ft. of rentable space in five states, and the initial public offering of City Office REIT, Inc.'s common stock. 

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.

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.

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.

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.

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.

Assisted numerous U.S. taxpayers residing both in the U.S. and abroad with tax compliance issues related to foreign bank/financial accounts, foreign trusts and other foreign business/investment entities. Advised numerous individuals in connection with making voluntary disclosures of their prior failure to file required U.S. tax/financial information returns (such as the “FBAR” Form, as well as Forms 5471, 3520 and 8938, etc.) and how to address  previously unreported U.S. tax liabilities.