Henrik Haeckel
Tax Partner @Hirschler
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WORK HISTORY
Tax Partner @Hirschler
Tysons Corner, VA, US
Corporate: Draft and negotiate tax sections of stock purchase agreements for C corporations and S corporations for buyers and sellers. Analyze the applicability of section 338(h)(10) elections and model their tax consequences. Advise on transaction deductions and maximizing tax efficiencies and attributes in transactions. Advise on tax reporting for corporate transactions. Advise on certain employment tax issues related to transactions, including deducting deferred compensation payments by sellers for pre-closing tax periods. Advise clients with respect to S corporation status and section 1202 stock. Advise client on successfully mitigating mistaken section 338(h)(10) election, which will save client millions in paymentsPartnerships:Draft operating agreements, including targeted allocation agreements for real estate partnerships and private equity funds. Advise on operating agreement structuring and tax implications. Draft and negotiate unit purchase agreements for buyers and sellers. Advise buyers and sellers on tax implications of unit purchase agreement tax provisions and structure. Assist clients with Bipartisan Budget Act (“BBA”) partnership audits. Negotiate provisions related to BBA in operating agreements. Model various partnership tax consequences of structures or transactions. Advise clients regarding debt allocations under section 752 (guaranteed or non-recourse nature) as well as with respect to section 704(c) considerations.International: Advise clients on international tax issues related to both inbound and outbound investments from a U.S. federal income tax perspective. Advise clients related to foreign trust reporting issues.Representative Transactions: Advised seller of domestic government services business to Japanese buyer on U.S. tax issues for a $177m transaction. Advised buyer on a partnership transaction with an enterprise value of $450m.
EDUCATION
Northwestern University Pritzker School of Law
JD
Columbia University
BA, Political Science
SKILLS
ABOUT HENRIK HAECKEL
Tax attorney with knowledge of partnership taxation, corporate taxation, international tax and financial product taxation.
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