Peter A. Igel

Tax, Mergers & Acquisitions

• Advised Kid Works Creative Learning Centers in the sale of the business to a large national operator of childcare centers, including the sale of four associated real-estate properties to a different third-party buyer, boosting transaction value for our client
• Represented publicly traded and privately held corporations in taxable acquisitions and dispositions (“F Reorganizations”), as well as tax-free transactions using mergers, stock swaps, stock for assets exchanges, spin-offs, and other creative structures
• Worked with bankruptcy partners to restructure troubled businesses using methods to avoid tax on debt forgiveness
• Drafted LLC operating agreements and limited partnership agreements with sophisticated distribution waterfalls, income/loss allocations, and built-in gains allocations
• Obtained Private Letter Rulings from the Internal Revenue Service to guarantee tax consequences before entering into transactions
• Defended taxpayers in audits, appeals, and litigation in federal income and estate taxes up to the U.S. Tax Court
• Defended taxpayers in Ohio sales, income, commercial activity, corporate franchise, and personal property tax cases up to the Ohio Supreme Court

Public Finance

• Advised issuers, underwriters, and conduit borrowers on tax issues involved in general obligation issues, industrial revenue bond financing, and qualified 501(c)(3) financing in transactions up to $1 billion
• Advised governmental entities and developers on structure of public/private partnerships
• Served as bond counsel in Ohio’s largest issue of Recovery Zone Economic Development Bonds after passage of the 2009 Stimulus Bill
• Arranged combinations of tax-exempt and taxable financing of major league and minor league professional sports stadiums based upon anticipated levels of public versus private debt service

Exempt Organizations and Healthcare

• Advised healthcare providers and other tax-exempt organizations on internal reorganizations and minimization of unrelated business income
• Advised exempt organizations participating in joint ventures with for-profits on protecting their tax-exempt status and avoiding unrelated business income
• Formed, obtained tax qualification, maintained, and dissolved dozens of private foundations for wealthy families and advised on proposed related party transactions
• Serve as outside counsel for a professional trade association

White Collar Defense and Investigations

• Obtained acceptance into an IRS voluntary disclosure program for a taxpayer holding undisclosed offshore investment accounts and real estate interests
• As co-counsel, examined substantive tax issues affecting clients under investigation to reduce tax deficiencies and offense levels

Estates, Trusts and Probate

• Helped high net worth individuals save estate and gift taxes through the establishment of GRATs, CLATs, CLUTs, CRUTs, sales to grantor trusts, and other tax reduction techniques
• Preserved the discount claimed on a family limited partnership in a $2-million estate tax case; a fresh look revealed a novel legal argument which persuaded the IRS to settle