James F. Millea Jr. is a partner in Holland & Knight's Boston office and a member of the Business Law Section. Mr. Millea's practice focuses primarily on corporate and partnership taxation. His experience includes addressing the federal tax treatment of corporate mergers, acquisitions, and spin-offs, as well as the treatment of the issuance of stock in both private and public offerings, and the issuance of debt. He also has experience advising corporations and corporate shareholders on general tax planning matters, including treatment of foreign investments. He advises closely held corporations on the effects of subchapter S and the limitations applicable to personal holding companies and the passive foreign investment companies.
Mr. Millea has broad experience with partnership transactions, including business joint ventures and the syndication of interests in commercial and residential real estate investments generating rehabilitation tax credits, new markets tax credits and low-income housing tax credits and the syndication of energy facility investments generating solar and renewable energy credits.
Mr. Millea also has considerable experience in the tax aspects of tax-exempt financing. He represents issuers of tax-exempt debt, including the Commonwealth of Massachusetts, and borrowers, including educational organizations, health care providers, and private owners of residential, solid waste and manufacturing facilities. He represents buyers of tax-exempt debt, including mutual funds and works extensively with mutual funds on restructuring defaulted tax-exempt bonds to assure retention of the bonds' tax-exempt status.
Mr. Millea represents taxpayers under both federal and Massachusetts tax audit. He has obtained private letter rulings from the National Office of the Internal Revenue Service on the tax consequences of prospective business transactions.
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