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Overview

I keep a close eye on the bottom line. My goal is to maximize my  clients’ tax savings, while minimizing their potential tax audit risks.

As part of his sophisticated tax practice, Henrik advises clients on the tax implications of a broad range of corporate and partnership transactions. He routinely assists with tax structuring and analysis of private equity acquisitions and exits. Leveraging 17 years of cross-border transactional experience, Henrik also counsels foreign businesses on U.S. tax issues and reporting obligations, and U.S. businesses on U.S. tax considerations related to their foreign activities.

Henrik advised clients on numerous transactions from sell side and buy side perspective focusing on potential tax exposures related to transaction and the seller or buyer. Among the issues Henrik advised clients on are the implications of earn-outs (installment sale tax treatment and imputed interest charges) and accounting method changes (acceleration of recognition income). In addition, Henrik drafts tax sections of partnership agreements with a focus on clarity and administrability of the provisions. To this end, Henrik works through client waterfalls and models to capture the economics in the agreements.

On the international side, Henrik advised clients with respect to foreign tax filings in particular focusing on issues related to Form 3520 and Form 3520-A filings and attendant IRS tax controversy.

Henrik is adept at deconstructing complex tax issues for clients to enable them to make informed decisions. In addition to understanding the tax issues involved in transactions, Henrik also understands the tax issues involved in operations. As a result, he provides his clients with comprehensive U.S. tax advice.

Prior to joining Hirschler, Henrik practiced at Flott & Co., P.C. in Arlington, Virginia. During a hiatus from law firms, he worked as a mergers and acquisition senior tax manager at EY and as an international tax manager at KPMG. During his legal career, Henrik has worked at large and mid-size law firms in Chicago, Washington and Denver.

Experience

Experience

Resolved Form 3520 and Form 3520-A penalties assessed by the Internal Revenue Service.

Negotiated partnership agreement provisions for investor in private equity fund.

Negotiated partnership investments for tax-exempt investors in partnership investment vehicles.

Drafted partnership agreement with special allocation provisions.

Advised, negotiated, and drafted tax provisions of a sale of multinational private equity portfolio for $540 million.

Advised, negotiated, and drafted tax provisions of purchases of S corporations with section 338(h)(10) elections and accounting method changes.

Represented U.S. taxpayers living abroad with U.S. tax reporting and U.S. tax planning issues.

Represented several portfolio companies with U.S. tax reporting and U.S. tax structuring issues.

Represented foreign multinational in establishing new U.S. operations involving maritime shipping.

Represented distressed REIT in the resolution of tax issues in $4.4 billion workout.

Represented client in a $19.58 billion acquisition of multinational Swiss headquartered IT company by US technology company.

Represented government contractor acquirer with respect to U.S. tax issues in $5 billion reverse Morris Trust acquisition of other government contractor business.

Advised hotel chain on U.S. tax aspects of foreign intellectual property holding structure.

Summarized U.S. tax consequences of acquisitions and dispositions of certain portfolio investments of a marque private equity fund.

Represented a partnership debtor in $5 billion Chapter 11 workout.

Drafted tax disclosures for regulated investment companies (“RICs”) for their SEC filings.

Rendered tax opinions on qualification of RIC mergers as tax-free reorganizations for U.S. tax purposes.

Analyzed the U.S. tax qualification of securitizations of mortgage backed securities as “real estate mortgage investment conduits.”

Perspectives

Community

Community

Professional Affiliations

D.C. Bar Association, Tax Section

Virginia State Bar, Tax Section

Continuing Legal Education Programming for Tax Section of Virginia State Bar, Board Member

VSB Tax Reporter for Tax Section of Virginia State Bar, Board Member 

Beyond the Law

Beyond the Law

When not chasing his two kids around in his free time, Henrik almost obsessively follows basketball and football. Proud of his Washington Heights roots, he roots for his New York Knicks, Jets, and Brooklyn Nets, and, consequently, has had a painful fandom life. To counter this suffering, Henrik swims at least 4 kilometers a week hoping someday to swim.

Northwestern University School of Law, J.D.

Columbia University, B.A. 

Heinrich Heine Universität, Germany 

  • District of Columbia
  • Virginia 
  • German
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