Austin Carlson

Partner @Gray Reed

Houston, TX, US

Corporate and Tax Counsel on Mergers and Acquisitions and Real Estate Joint VenturesPrimary deal lawyer and special tax counsel on numerous transactions ranging in size of up to $1B.Successfully represented sponsors of numerous small-midsized funds or single asset acquisition entities including creation of partnership agreements and structuring of tax efficient investment strategies for investors and sponsors.International and Domestic U.S. Tax ControversyRepresented more than 1,200 taxpayers in foreign asset and income disclosure matters including Streamlined Filing Compliance Procedures cases, voluntary disclosures, disclosures pursuant to the Delinquent International Information Return Submission Procedures and Delinquent FBAR Submission Procedures.Successfully abated more than of IRS penalties including penalties for delinquent filing of Forms 3520, 3520-A, 8938, 8621, 5471, 5472, and FBARs.Complex Domestic and International Transactional Tax PlanningSuccessfully assisted with structuring millions of dollars of inbound U.S. investment through creations of tax efficient U.S. investment structures for foreign companies doing business in the U.S. and foreign investors investing in U.S. real estate and other U.S. business ventures.Advised on and closed millions of dollars of QOF investments including complex structuring transactions involving related parties, land already owned in QOZs, and cryptocurrency planning.Represented a client in numerous 1031 exchanges involving transactions with several tax partnerships owning several multimillion dollars relinquished properties exchanging into several tenants in common interests in multimillion dollars replacement properties.Represented a family office in the purchase of a ranch in Briscoe County, Texas through a reverse 1031 exchange.