John Stern focuses his federal income tax practice on the structuring, formation, and operation of private investment funds, single- and multi-asset joint ventures, coinvests, and other collective investment vehicles. He regularly advises sponsors of private equity, venture capital, and hedge funds on their organization and ongoing operations, and has extensive experience advising real estate fund sponsors and investors, including on complex issues involving REITs and FIRPTA. In particular, John has advised on transactions involving both equity and mortgage REITs investing across sectors within the real estate industry, private and publicly traded REITs, REIT operational and compliance challenges including “prohibited transaction” issues, sales of private REIT stock, and more.
John provides advice regarding tax efficient structures designed to accommodate investment by limited partners with various tax sensitivities, including non-US investors, qualified foreign pension funds, sovereign investors eligible for exemption under Code Section 892, non-U.S. investors seeking tax treaty eligibility, domestic tax exempt and “super” tax exempt investors, and others.
In addition, John advises private fund sponsors on structuring their general partner and management company activities, including in regards to carried interest, equity compensation arrangements and tax efficient grants of profits interests. Fund clients also look to John for advice on restructurings, continuation vehicles, limited partner secondaries, sales of management company interests, and other transactions.
John also represents limited partners in connection with their investments in private funds across various sectors, bringing a holistic and practical perspective to his work.
Affiliations
- Member, Boston Bar Association