Bio Filter Option

Richard C. LaFalce

合伙人

richard.lafalce@morganlewis.com

Washington, DC 电话 +1.202.739.5506 Fax +1.202.739.3001

1111 Pennsylvania Ave. NW//Washington, DC 20004-2541//United States

Richard C. LaFalce counsels clients on the creation and taxation of private and pooled investment vehicles such as mutual funds, ETFs, REITs, real estate funds, private equity funds, Opportunity Zone Funds, and other investment-related entities. He frequently advises clients on the taxation of financial products, the unrelated business income tax (UBIT), as well as general corporate and international tax matters. Before joining Morgan Lewis, Rich was an assistant branch chief in the Internal Revenue Service Office of Chief Counsel, Financial Institutions and Products.

Rich advises clients on general corporate tax matters, the taxation of financial products, information reporting, and international tax planning. He also counsels companies on international tax issues including compliance with the Foreign Investment in Real Property Tax Act (FIRPTA).

Rich frequently assists clients in their interactions with the IRS including obtaining Private Letter Rulings and other guidance.

A frequent speaker, Rich presents on a variety of tax topics at the American Bar Association’s Tax Section meetings, and for the Federal Bar Association, District of Columbia Bar Association, and the Practicing Law Institute.

奖项与社会关系

Member, Best ETF Law Firm, ETF Express US Awards (2021)

Member, ETF Law Firm of the Year, ETF.com (2019)

Member, Best ETF Legal & Compliance Firm, ETFexpress (2019)

Member, Practice Group of the Year, Tax, Law360 (2017)

Former Chair, American Bar Association, Section of Taxation, Investment Management Committee

执业资格

  • District of Columbia
  • New York
  • U.S. Tax Court

教育背景

  • The George Washington University Law School, 2005, J.D.
  • College of William & Mary, 2001, B.A.

行业部门

  • Investment Funds

执业领域

  • Capital Markets & Public Companies
  • Tax
  • Investment Management
  • Corporate, Finance & Investment Management
  • Real Estate
  • Opportunity Zone Funds

地区

  • North America

Events

11/1/2021 - ICI’s Virtual Securities Law Development Conference
6/30/2021 - Foreign Withholding Tax Recovery
12/13/2019 - Qualified Opportunity Funds: What You Need to Know About Year-End Deadlines
8/1/2019 - New Paths Forward: Precidian’s Activeshares® and The Conversion Of Mutual Funds To ETFs
6/13/2019 - 2019 Morgan Lewis Advanced Topics in Hedge Fund Practices Conference: Manager and Investor Perspectives – Boston
6/11/2019 - 2019 Morgan Lewis Advanced Topics in Hedge Fund Practices Conference: Manager and Investor Perspectives
5/7/2019 - 2019 Morgan Lewis Advanced Topics in Hedge Funds and Other Alternative Funds Conference – Chicago
2/26/2019 - Investment Company Institute (ICI) Tax Committee Meeting
2/12/2019 - Institute for Portfolio Alternatives (IPA) Forum: Qualified Opportunity Zone Funds
1/17/2019 - ABA Tax Section 2019 Midyear Tax Meeting
11/14/2018 - Qualified Opportunity Zone Funds
9/17/2015 - ABA 2015 Joint Fall CLE Meeting

News

6/5/2020 - The IRS Is Giving You More Time to Invest in This New Tax-Advantaged Strategy, CNBC
6/4/2020 - IRS Grants Pandemic Deadline Relief On Opportunity Funds, Law360
12/31/2019 - Time Is Almost Up for Maximizing This Hot New Tax Play, CNBC.com
4/22/2019 - Developers Get More Time with Opportunity Fund Safe Harbor, GlobeSt.com
4/18/2019 - New Proposed O-Zone Regs May Be the Last, Officials Say, Tax Notes
4/27/2017 - Morgan Lewis Advises Gramercy Property Trust in $285.7 Million Public Offering
10/19/2016 - Top Tax Lawmakers Counter IRS 10-Year REIT-Conversion Proposal, BNA's Daily Report for Executives
10/3/2016 - Proposed RIC Rules Look to SEC to Define Security, Tax Analysts
6/16/2016 - Morgan Lewis Elects 33 New Partners
4/9/2015 - Morgan Lewis Advises Gramercy Property Trust Inc. in $235 Million Public Offering
12/16/2014 - Morgan Lewis Advises Gramercy Property Trust Inc. in Closing of Common Stock Public Offering

Publications

6/15/2022 - Bipartisan Proposal Attempts to Provide Solutions for Comprehensive Regulation of Digital Assets
9/22/2021 - Tax Proposals May Affect Exchange-Traded Funds
1/25/2021 - IRS Extends Previously Issued Relief to Qualified Opportunity Funds and Their Investors
6/23/2020 - IRS Provides COVID-19 Pandemic Relief for Qualified Opportunity Zone Investments
5/15/2020 - COVID-19 Considerations for RICs and REITs and Temporary Relief on Certain Stock Distributions
4/15/2020 - IRS Releases REMIC and Trust Relief Guidance for COVID-19 Emergency-Related Mortgage Forbearance and Modifications
6/4/2019 - IRS Proposes Regulations for Withholding on Transfers of Partnership Interests
4/19/2019 - IRS, Treasury Issue Second Set of Proposed Rules on Qualified Opportunity Zone Funds
3/25/2019 - Final Regs Reverse Proposed Mutual Fund Income Funds, Tax Notes
3/20/2019 - IRS, Treasury Issue Final Guidance Regarding Certain Investments by RICs
10/23/2018 - Opportunity Zone Fund Regulations – Long-Awaited Guidance Should Help Investors and Sponsors Get Off the Sidelines
4/20/2018 - IRS, Treasury Issue Guidance on ‘Business Interest Expense’ Limitation
3/12/2018 - IRS Provides Guidance on Tax Treatment of Insurance Products
8/24/2017 - IRS Issues Guidance on RIC and REIT Stock Distributions
12/21/2016 - US FATCA: Deadline to Register Sponsored Entities Approaching
12/20/2016 - Filing Deadline Extended for Certain FBAR Filers
9/30/2016 - IRS and Treasury Issue Guidance Regarding CFC and PFIC Investments by RICs
8/1/2016 - IRS Announces Fines Paid to FINRA Are Not Deductible
6/22/2016 - FinCEN Extends Filing Deadline for Certain FBAR Filers
June 10, 2016 (Updated February 6, 2017) - IRS Issues Temporary and Proposed Regulations Focused on REIT/RIC Conversion Transactions
5/24/2016 - IRS Offers Tax Guidance Relating to Money Market Fund Rules
3/4/2016 - FBAR Proposed Regulations Expand Both Filing Exemption and Reporting
1/27/2016 - IRS Publishes Guidance for RICs that Receive Foreign Tax Credit Refunds
1/5/2016 - New PATH Act Changes Rules for Foreign Investment in US Real Estate and for REITs
10/14/2015 - IRS Delays Effective Date for New Regulations on Embedded Loans in Swaps
9/18/2015 - Thinking About Converting to a RIC? Important Considerations
4/1/2015 - A Tale of Two ‘‘Pauses’’: The IRS’s Halt in Issuing Private Letter Rulings for MLPs and RICs, BNA Tax Management Real Estate Journal
1/26/2015 - FinCEN Again Extends Deadline for Certain FBAR Filers
5/7/2014 - IRS Announces Transitional Period for FATCA Enforcement, Other FATCA Rule Changes
4/10/2014 - Initial FATCA Registration/Withholding Dates Draw Near
1/14/2014 - FinCEN Announces Extension for Certain FBAR Filers
9/20/2013 - Panelist, Current Issues Confronting Regulated Investment Companies (RICs), presented at the ABA Section of Taxation and Section of Real Property, Trust and Estate Law, Trust and Estate Division 2013 Joint Fall CLE Meeting, San Francisco
1/4/2013 - FinCEN Announces Third Extension for Certain FBAR Filers