JOSEPH C. MANDARINO is a Partner in the Atlanta office. Mr. Mandarino’s practice focuses primarily on tax planning for business entities and their owners. He is involved with a wide variety of taxpayers and transactions, and has experience in

• structuring M&A transactions, from both the buyer and seller sides,
• energy and utility tax issues,
• negotiating executive compensation arrangements that qualify for favorable tax treatment,
• workouts and bankruptcy,
• corporate and partnership taxation,
• financial products,
• tax aspects of real estate development and like-kind exchanges,
• international transactions (both inbound and outbound), and
• tax-exempt organizations

In addition to transactional work, Mr. Mandarino has represented taxpayers in tax controversy work, including tax audits, appeals, National Office submissions, and regulatory hearings, as well as Tax Court and District Court litigation

Mr. Mandarino writes and speaks on a variety of tax topics. His articles have appeared in the National Law Journal, Mergers & Acquisitions magazine, Tax Notes Today, the Journal of Real Estate Taxation, the Journal of S Corporation Taxation, the Journal of Multistate Taxation, Tax & Finance Newsletter, and the NYU Institute on Federal Taxation. In addition, he has spoken at meetings and seminars organized by numerous organizations, including the American Bar Association, the White House Conference on Small Business, the U.S. Small Business Administration, the Georgia Electronic Commerce Association, the Federation of Exchange Accomodators, the International Reinsurance Conference, the Service Corps of Retired Executives, the American Health Lawyers Association, the Southeaster Health Law and Policy Forum, and the United Way, as well as several panel-type TV discussion programs.

Recent and representative transactions include:

• $4.25 billion acquisition of the assets of a Japanese consumer lending corporation
• $1.3 billion acquisition of interests in broadband technology joint venture
• $1.3 billion acquisition of credit card receivables portfolio
• $1 billion acquisition of the assets of a Japanese life insurance company
• $610 million disposition of transmission assets from regulated utility
• $540 million acquisition of the stock of a U.S. life insurance company
• $325 million stock acquisition of domestic equity REIT
• $180 monetization of oil and gas assets
• series of related electrical utility project finance acquisitions totaling of $178 million
• $120 million acquisition of credit business through a leveraged partnership
• $118 million REIT acquisition of a portfolio of apartment properties
• $83 million liquidating distribution of partnership interest
• IRS audit of executive compensation arrangements
• IRS CEP audit of large urban hospital system
• IRS audit of mid-sized suburban hospital system
• IRS submission on power facility taxation issue for national coalition of utilities
• IRS submission on normalization issues for major U.S. utility