Michael G. Frankel, Ernst & Young LLP, National Tax Department, Miami, Florida. Mike is the Global and Americas Tax Leader of Ernst & Young LLP's Real Estate Sector. Mike has over 34 years of experience as a federal income tax advisor. During that time, he has represented publicly- and closely-held corporations, as well as publicly traded and privately owned general and limited partnerships, joint ventures and limited liability companies. Mike has also represented public and private pension funds and real estate investment funds comprised of both domestic and foreign investors.
Mike's practice centers around the structuring, restructuring and negotiation of business transactions from both a tax and non-tax standpoint. Mike's corporate representation includes (i) the structuring of taxable and nontaxable stock and asset purchases for both purchasers and sellers; (ii) planning for and implementing exit strategy techniques, including spin-offs, split-offs and redemptions; (iii) structuring leveraged ESOP financings; (iv) planning for debt workouts and restructurings (including preservation of net operating losses); and (v) structuring real and phantom equity plans to provide meaningful monetary incentives for key executives.
Mike's real estate and partnership practice centers primarily upon (a) the structuring and negotiation of complex partnership arrangements; (b) providing advice on tax deferred like-kind exchange and installment sale transactions; (c) unwinding partnership arrangements on a tax-deferred basis; (d) forming and financing real estate investment trusts; and (e) helping real estate owners and developers navigate through the troubled tax waters of workout transactions.
Prior to joining Ernst & Young LLP, Mike was a partner in the Real Estate Industry Tax Group of PricewaterhouseCoopers LLP, where he served as the Tax Services Leader for the Americas for both the Real Estate Industry and the Hospitality Industry from 1994-1999.
Mike is a graduate of the Wharton School of Finance and Commerce of the University of Pennsylvania and the University of Virginia Law School. He is a past Chair of the Committee on Partnerships of the American Bar Association Section of Taxation and is a past Chair of the Section of Taxation of the State Bar of Texas.