When introduced to potential new clients or existing client relationships, Howard often soon becomes that client’s trusted tax advisor. With a base of more than 40 years of US federal income tax knowledge, Howard is able to not only structure transactions in a tax-efficient manner, but provide tax advice that makes good business sense. His tax practice has evolved over the years, enabling him to tap into a reservoir of experience when guiding clients through the complex maze of federal income tax law. In the early stages of his career, Howard represented two of the largest, publicly-traded leasing and finance companies in the country.
In that capacity, he helped structure equipment lease transactions, provided “true lease” tax opinions, and drafted and negotiated tax indemnity agreements in connection with leveraged aircraft lease transactions. He has also represented those and other public companies before the IRS Office of Appeals as part of their regular IRS audit cycles.
In more recent years, Howard has become the firm’s lead tax attorney supporting its private equity and hedge fund practice that entails representation of both fund sponsors and institutional investors. In addition, he is one of the go-to attorneys in the firm when tax advice is needed to properly structure and document mergers and acquisitions, joint ventures, equity investments, dividend recapitalizations and the like. Because Washington, DC is a hub for non-profit organizations, Howard also regularly provides advice to large tax-exempt organizations regarding unrelated business income tax issues and preservation of tax-exempt status.
Professional Activities
- American Bar Association, Taxation Section
- District of Columbia Bar Association, Taxation Section
Honors and Awards
Recognized in The Best Lawyers in America (BL Rankings) in the fields of Real Estate Law, Tax Law, 2013 – 2017, 2021
Experience
Any result the lawyer or law firm may have achieved on behalf of clients in other matters does not necessarily indicate similar results can be obtained for other clients.
- Represented two large institutional investors, one a private foundation and the other a governmental entity, in connection with over $10 billion of private equity, hedge fund and other alternative investments, including review and negotiation of tax-related provisions in fund agreements and side letters.
- Provided tax structuring advice and drafted and negotiated tax indemnity and covenant provisions for large public company payment processing entity, in more than 35 merger and acquisition transactions.
- Served as tax counsel to two middle-market private equity fund sponsors based in Charlotte, North Carolina in connection with their acquisition and disposition of numerous portfolio companies with an aggregate value of $2 billion.
- Served as US tax counsel, and delivered income and withholding tax opinions, to one of the largest European-based airlines in connection with its Export-Import Bank-financed acquisition of dozens of Boeing 737 aircraft.
- Serve as tax counsel to the United States branch of a large, international religious organization recognized by the IRS as a tax-exempt church.
