Stephen B. Land

Partner

Stephen Land, who is one of the top international tax lawyers in the United States, is Chair of the Firm’s Tax Practice. Mr. Land is known for his creative problem-solving approach and his responsiveness to client needs. He has brought those skills to bear on some of the largest international M&A transactions and restructurings of distressed assets and companies. He regularly advises on tax and ERISA for real estate, private equity, and hedge funds and their investors, regarding both the structure of the funds and their investments. He also has extensive experience in the structuring of complex financial instruments and derivatives.

Recognized as a thought leader in the field, Mr. Land speaks regularly on tax topics at conferences in the United States and elsewhere. He is a recent Chair of the Tax Section of the New York State Bar Association, and has been published in The Tax Lawyer and Tax Law Review, among others. Mr. Land has been recognized as a leading tax practitioner by Chambers, Legal 500 and other legal directories.

Mr. Land’s principal papers provide novel insights into some of the knottiest problems of the tax law. They can be accessed through the links under “Publications” below.

Mr. Land routinely advises our real estate clients on the following:

• Formation of tax-efficient structures;

• Negotiating fund-operator joint ventures;

• New York State and City Transfer Taxes;

• Foreign investment in US real estate (including avoiding FIRTPA for foreign investors);

• Structures for investment in non-US real estate and debt;

• Real estate fund formation;

• Fund manager compensation;

• Complex equity participations and debt restructurings;

• Avoiding cancellation of indebtedness income;

• Arranging tax-free like-kind exchanges;

• Tax-exempt investors (including UBTI and fractions rule compliance);

• Managing REIT compliance; and

• ERISA investors (including VCOCs and REOCs).

He also regularly advises our non-U.S. clients on a myriad of issues relating to investments in the United States, including the following:

• Securing treaty benefits;

• Avoiding being engaged in a “trade or business” in the U.S.;

• Minimizing withholding tax burdens;

• Navigating anti-deferral regimes such as the PFIC and CFC rules;

• Integrating U.S. and foreign tax planning to minimize overall tax burdens;

• Dealing with FATCA and other foreign accounts reporting; and

• Preserving exemptions for foreign pension and sovereign wealth funds.

Mr. Land is licensed in New York.

Prior to joining the firm, Mr. Land was a partner in the New York office of Linklaters.  Before that, he practiced at Howard, Darby & Levin (now part of Covington & Burling) and Sullivan & Cromwell. Mr. Land is admitted to practice only in New York.

Recognitions:

• Chambers USA, Tax, and Chambers Global, International Tax

• Legal 500 US, International Tax

• The Best Lawyers in America, Tax Law and Litigation and Controversy – Tax (2011 - 2022)

• New York Super Lawyers, Tax Law: 2012 - 2021

Associations:

• Fellow, American College of Tax Counsel

• New York State Bar Association, Tax Section, Former Chair

• Tax Forum

• Tax Review

 Publications:

• Treaty Consistency, The Tax Lawyer (2012)

• Report on Proposed and Temporary Regulations Under Section 871(m), New York State Bar Association (2012)

• Entity Identity: The Taxation of Quasi-Separate Enterprises, The Tax Lawyer (2009)

• Report on “Zero Basis”, New York State Bar Association (2006)

• Report on Disclosure by Material Advisors, New York State Bar Association (2005)

• Bearer or Registered? Lingering Issues under TEFRA, The Tax Lawyer (2005)

• Revaluations Revisited, The Tax Lawyer (2001)

• Defeating Deferral: A Proposal for Retrospective Taxation, Tax Law Review (1996)

• Strange Loops and Tangled Hierarchies, Tax Law Review (1993) 

• Partnership Revaluations, The Tax Lawyer (1989)

• Contingent Payments and the Time Value of Money, The Tax Lawyer (1987)

• Unallocated Premium in Corporate Acquisitions, The Tax Lawyer (1981)

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