Raj Tanden is a tax partner with Foley & Lardner LLP where he represents clients in tax matters across a broad spectrum of domestic and cross-border transactions.

Raj chairs Foley’s Investment Management Tax Practice and specializes in tax planning for private equity fund managers in connection with the structuring and investment activities of their private funds and other investment management transactions, including significant experience structuring cross border private credit funds. Raj also chairs the firm’s New England and Southern California Tax Practices and has almost thirty years of experience in M&A transactions.

Raj is a fellow of the American College of Tax Counsel, comprised of the leading 700 tax lawyers nationwide, and of the American Bar Foundation, which consists of the top one percent of lawyers in each state. Raj was selected by his peers for inclusion in The Best Lawyers in America© in the field of Tax Law (2009, 2017-2022) and listed with Southern California Super Lawyers®.

IRS Private Letter Rulings Experience

Raj has received several, innovative Internal Revenue Service (IRS) private letter rulings on behalf of clients, including:

  • One of the first rulings that a publicly-registered, non-traded REIT may adopt a “multi-class” structure similar to those used by mutual funds
  • Other rulings applicable to REITs, including that a target C corporation may issue a note to distribute out all of its historic “earnings and profits” before its acquisition by a REIT, as long as the target’s historic business and assets would be used to repay the note after the acquisition
  • Rulings on behalf of public investment funds, including the following: the first rulings issued by the IRS that an acquiring mutual fund need not retain any assets of a target fund under the “continuity of business enterprise” doctrine; and that cancellation of indebtedness income would constitute qualifying income
  • Rulings that taxpayers subject to SEC Rule 144A restrictions on the sale of stock in a publicly-traded company may use the “installment method” for the sale, even though the method cannot be used for publicly-traded property
  • Rulings on like-kind exchanges, including the following: a tenant may exchange commercial leasehold interests where a third-party would pay a substantial sum to build out the tenant’s new space (also known as a “build to suit”); and an accommodator would not be disqualified from completing like-kind exchanges for paying a referral fee to brokers who also own equity in the accommodator

Representative Clients

  • AXA Investment Managers: the investment arm of AXA S.A.

  • Comvest Partners: a Florida middle market fund sponsor
  • FAT Brands: a Los Angeles publicly traded restaurant franchisor
  • Five Elms Capital: a Midwest growth equity fund sponsor
  • iCapital Network: an alternative investment marketplace with approximately $74 billion in platform assets
  • Monroe Capital: a Chicago private credit asset management firm
  • Trilogy Real Estate Group: a Chicago alternative investment fund sponsor specializing in real estate


Raj earned his LL.M. in tax from the New York University (NYU) School of Law (1996) and his J.D. from the University of Southern California (USC) Gould School of Law (1992). His undergraduate degree was conferred by the USC Leventhal School of Accounting (B.S., 1988).

Admissions, Professional Memberships, Publications and Speaking Engagements

Raj is admitted to practice in California and Massachusetts.

Raj is a member of the Executive Committee of the USC Tax Institute. He is also a past chair of the American Bar Association (ABA) Tax Section Investment Management Committee. He has authored numerous articles and speaks for the ABA, American Law Institute, NYU Federal Tax Institute, Practising Law Institute and USC Tax Institute.

Community Engagement

Raj is an avid cyclist. He is a member of the La Grange cycling club in Los Angeles. He has completed the 2019 AIDS/LifeCycle Ride, a 545-mile/7-day bike ride from San Francisco to Los Angeles to raise funds for the life-saving services offered by the San Francisco AIDS Foundation and the Los Angeles LGBT Center, and the Pan-Mass Challenge, a 200-mile/2-day ride through central Massachusetts to the Provincetown (Cape Cod) to raise funds for the Dana Farber Cancer Institute. Raj has also climbed the Haleakala volcano on Maui on a number of occasions: an over 10,000 ft. climb!