Tax, Employee Benefits & Global CompensationNot-For-Profit OrganizationsCapital Markets
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New York Direct: 212.830.7258 General: 212.790.4500 Fax: 212.790.4545
New York University School of Law, LL.M. (Taxation), 1991
Columbia Law School, J.D., 1987Harlan Fiske Stone Scholar, 1984–85; 1985–86Writing and Research Editor, Columbia Journal of Law and Social Problems
Brown University, A.B., magna cum laude, 1984
Michael Lehmann specializes in tax issues relating to the tax treatment of cross-border transactions. He advises foreign and domestic organizations on cross-border joint ventures and investments, tax treaty planning, taxation of international transportation activities, and debt and equity offerings of non-U.S. companies.
His practice also includes a wide variety of state and federal income tax issues arising from domestic corporate acquisitions and reorganizations, and state and federal tax controversies, and has particular expertise in the area of tax-advantaged transactions such as New Markets Tax Credits, Low-Income Housing Tax Credits and Energy Tax Credits.
Prior to joining Manatt, Mr. Lehmann amassed significant experience providing tax structuring advice in cross-border transactions, both outbound and inbound.
U.S. outbound issues included foreign tax treaty networks; use of offshore corporations; foreign tax credits; controlled foreign corporations and Subpart F income; passive foreign investment companies; foreign tax concessions and incentive programs; mergers, acquisitions and dispositions of foreign subsidiaries; tax issues for expatriate employees; transfer pricing and related party transactions; and debt versus equity structuring.
U.S. inbound issues included U.S. tax treaty planning and interpretation, particularly "permanent establishment" issues; "effectively connected income" from U.S. business activities; portfolio income and U.S. withholding taxes; choice of entity for U.S. business activity (corporation, partnership, LLC, business trust); real estate activities and "FIRPTA"; and tax issues for bringing employees into the United States.
Co-Author, "Borrowing on Margin Treated as Unrelated Debt-Financed Income," Taxation of Exempts, May/June 2010 (with K. Kerry).
Co-Author, "IRS Issues Notice 2010-41 Outlining Regulations to be Issued that will Treat Domestic Partnerships as Foreign Partnerships under the Controlled Foreign Corporation Rules," Practical International Tax Strategies, Volume 14, No. 9, May 2010.
Co-Author, "IRS Continues Push Against Perceived Abuses in the International Arena by Redemptions through Controlled Corporations," Practical U.S./International Tax Strategies, Volume 14, No. 3, February 2010.
Author, "IRS Ruling Illustrates Neighborhood Land Rule," Real Estate Taxation, 1st Quarter 2010.
Co-Author, "IRS Permits Debt Treatment for Trust Preferred Securities with "Significantly More" Equity Characteristics," Practical U.S./International Tax Strategies, Volume 9, No. 9, September 2009.
Co-Author, "UBIT and Privately Funded Scientific Research," Taxation of Exempts, July/August 2009.
Co-Author, "Obama Administration Takes Aim at Inversion Transactions with Enhanced Surrogate Foreign Corporation Rules," Practical U.S./International Tax Strategies, Volume 13, No. 10, May 2009.
Co-Author, "New Markets Tax Credits Stimulate Community Development," Taxation of Exempts, September/October 2008.
Author, "UBIT Developments for 2007," Taxation of Exempts, March/April 2008.
"Major Changes for Exempt Organizations in the Pension Protection Act of 2006," Journal of Taxation, Volume 106, No. 1, January 2007.
"Internal Revenue Service Issues Guidance Regarding Participation by Tax-Exempt Organizations in Low-Income Housing Tax Credit Projects," Real Estate Finance Journal, Winter 2007.
"Leasing and the Feeder Organization Rules," Taxation of Exempts, Volume 19, No. 3, November/December 2007.
Member, New York State Bar Association.
"What CFOs Need to Know About the Impact of President Obama's Offshore Tax Avoidance Proposal," May 8, 2009.
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