Frank A. Crisafi concentrates in tax law. He was formerly associated with a "Big Four" certified public accounting firm. His areas of concentration include corporate mergers and acquisitions, partnership taxation, real estate investment trust (REIT) taxation and international tax planning. He has experience in tax planning with respect to the organization of business entities, structuring and planning with respect to "tax-free" corporate reorganizations, as well as taxable dispositions of stock and assets with particular emphasis on financial institutions, including conversions of financial institutions to facilitate the making of a Sub-S election. He also represents and has represented a number of real estate developers and owner/operators, both in the establishment and restructuring of their operations and legal entities. The types of entities involved have included general and limited partnerships, limited liability companies, as well as special tax entities, including public and "private" REITs, as well as real estate mortgage investment conduit ("REMIC") servicers in connection with the transfer of real estate subject to pooled mortgage loans held by the REMIC.
In addition, he has substantial experience in handling matters at all stages before the Internal Revenue Service ("IRS") and other taxing authorities from the initiation of an audit, negotiation of cases with agents and their supervisors, the appeal of cases before the IRS and docketing cases in the U.S. Tax Court and other courts. The matters have included both domestic and foreign issues, transfer pricing issues, timing of deductions, worthless stock losses, and accounting method issues involving multi-million dollar tax assessments, including penalties. He has also defended taxpayers in "tax shelter" cases.
His principal clients include financial institutions and publicly-traded and privately-held REITs.