Lawyer Bio : Howard N. Solodky

Mr. Solodky has been a tax practitioner since 1977, commencing private practice in 1981. He has an extensive history of involvement in all tax aspects of commercial and residential real estate including like-kind exchanges, real estate leasing issues, choice of entity and the taxation of pass-through entities. He has primary Firm responsibility for tax structuring and drafting of tax allocation provisions for organizational documents of partnerships and limited liability companies formed for the Firm’s real estate clientele.

Mr. Solodky has substantial tax controversy and rulings experience at both the federal and state levels and has litigated several cases in the United States Tax Court. He has represented numerous publicly-traded and privately-held companies before both the Examination Division and the Office of Appeals of the Internal Revenue Service.

Mr. Solodky also has recurring involvement in the tax aspects of equipment, leveraged and synthetic leasing, with a particular emphasis on the aircraft leasing industry.

Illustrative of Mr. Solodky’s client engagements are the following:

• Represented before the LMSB division of the IRS and the IRS Office of Appeals two publicly-traded finance companies in several audit cycles, with issues ranging from the deductibility of aircraft overhaul expenses to the tax consequences of securitization transactions.
• Represented before the IRS Examination Division and Office of Appeals a large residential real estate developer and owner of a year-round resort in a tax audit that spanned seven years and involved uniform capitalization, depreciation and capital gains issues.
• Represented a publicly-traded finance company in a number of leveraged leases of commercial aircraft, which engagement included the preparation and negotiation of tax indemnity agreements and the delivery of “true lease” tax opinions.
• Represented a publicly-traded bank holding company and its insurance services subsidiary in a large number of wholly or partially tax-free acquisitions, including the preparation of approving tax opinions.
• Represented the sponsor of private equity funds that invest exclusively in timberland in the tax structuring and drafting of limited partnership agreements.