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Attorneys
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Attorney Profile
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Charles R. Beaudrot, Jr.
Partner
Phone: 404.504.7753
Fax: 404.365.9532
Email: cbeaudrot@mmmlaw.com
Charles R. Beaudrot, Jr. is a senior partner in the firm’s Tax Practice. Mr. Beaudrot’s areas of practice include corporate and partnership tax, transactional tax planning, state and local tax planning and tax controversy work. Mr. Beaudrot is also a partner in the Real Estate Capital Markets practice and advises clients with respect to tax issues involving real estate partnerships, real estate investment trusts and their related umbrella partnerships and tax efficient strategies for corporate owned real estate.
Mr. Beaudrot is a frequent speaker on tax, partnership and corporate topics for numerous sponsors such as the Georgia Society of Certified Public Accountants, the Institute for Continuing Legal Education in Georgia and the Georgia Real Estate Tax Conference. Mr. Beaudrot has been particularly active in the area of flow-through entities in Georgia, having participated in the drafting process for Georgia’s LLC and LLP legislation. Chambers USA, America’s Leading Business Lawyers: The Client’s Guide identifies him as among the nation’s leading tax attorneys, Legal 500 named him as a leading lawyer for real estate tax, Georgia Trend magazine identified him one of the state’s “Legal Elite,” Atlanta magazine has listed him as one of its “Super Lawyers,” and the Atlanta Business Chronicle has listed him in its Who’s Who in Law.
Mr. Beaudrot also teaches Contract Drafting as an Adjunct Professor at Emory University Law School’s Center for Transactional Law and Practice program.
Recent Experience
Structuring of ownership and implementation of $1.5 billion in sales of investment real property to
affiliated development entity to lock in capital gains and qualify for installment treatment
UBTI planning and implementation for $800 million real estate opportunity investment fund to acquire
distressed properties
Advice and implementation of S Corporation election utilizing expanded and relaxed S Corporation
election rules permitting family attribution to permit company with over 140 shareholders to elect S
Corporation status, including utilization of Electing Small Business Trust and Qualifying Subchapter S
Trust elections as well as addressing repositioning of stock held by impermissible stockholders and
addressing community property issues
UBTI and REOC planning and implementation for $200 million real estate investment fund
Tax planning for $50+ million tax deferred recapitalization treatment of internet based financial services
company including addressing issues of exchanges of “qualified preferred” and associated IRC Section
382 loss attenuation issues
Representation of $40 million multistate personal services company and its owner in audit asserting
alleged improper deductions and deemed dividend treatment to owner
Use of “drop down/freeze” LLC transaction to shift over $25 million in appreciation in asset values to C
Corporation owners, thus avoiding corporate level taxes on such appreciation
Representation of taxpayer and negotiation of settlement in connection with audit of closely held
corporation proposing deemed dividend treatment and disallowance of numerous business expenses
Representation of taxpayers in successful penalty waiver requests in connection with late filings by
affiliated entities totaling in excess of $2,000,000
Representation of non-resident partner in connection with voluntary disclosure and successful penalty
waiver request to the Georgia Department of Revenue
Bar Admissions
State Bar of Georgia, Admitted 1976
Education
Duke University, B.A., summa cum laude, 1973
Harvard University, J.D., cum laude, 1976
Phi Beta Kappa
Phi Eta Sigma
Angier B. Duke Memorial Scholar
Honors and Affiliations
Chambers USA: America's Leading Lawyers for Business - Listed as a top lawyer in Tax, 2003 – 2010
Legal 500 - Listed as a top lawyer for Real Estate Tax (2009)
Member, State Bar of Georgia
- Chair of Tax Section 1997-1998,
- Chair of the Business Law Section 2003-2004,
- Member Executive Committee - Business Law Section 2001-2005,
- Chair of the Partnership & LLC Committee - Business Law Section, 1996-2001
- Member of the Partnership & LLC Committee - Business Law Section, 1996-2009
- Member of the Legal Opinion Committee-Business Law Section and Corporate Counsel Section, 1990-2001
Member, Atlanta Bar Association
- Director of Tax Section, 1990-1992
- Chair of Tax Section, 1992-1993
Member, American Bar Association
Atlanta Tax Forum
- Trustee 1994-2000
- President 1998-1999
Member, National Association of Real Estate Investment Trusts (NAREIT)
Member, American Society of Composers and Publishers
Member, the National Academy of Recording Arts & Sciences
Selected, The Best Lawyers in America, 2009 - 2011
Former Member, Advisory Board for the Information Management Network's Private & Non-Traded REIT Industry Symposium
Publications
Author:
“Transactional Skills Training: Opinion Letters,” Transactions – The Tennessee Journal of Business Law, Special Report 2009
"Mega Trends and Current Issues in the Tax World." Inside the Minds: Common Issues in Tax Law: Leading Lawyers on Handling Tax Audits, Executing Tax Appeals, and Monitoring Client Tax Compliance. Chapter 4, Aspatore Books: June 2008
“Effective Use of Limited Liability Companies in Georgia: An Overview of Their Characteristics and Advantages,” 45 Mercer Law Review 25
“Limited Liability Companies” in Georgia Jurisprudence, Corporations, and other Business Organizations and Securities Regulation
Co-Author:
Georgia LLC/LLP Handbook
“Taxation of Receipts of Profits and Capital Interests In Connection With Performance of Services,” ABA Business Law Section Newsletter, August 13, 2009
More Publications
Latest Press Releases
6/16/2010 - Morris, Manning & Martin Recognized for Excellence by Chambers USA 2010
8/6/2009 - Morris, Manning & Martin Attorneys Recognized for Excellence by The Best Lawyers in America
6/17/2009 - Morris, Manning & Martin, LLP Recognized for Excellence by Chambers USA
4/27/2009 - Morris, Manning & Martin Attorneys Among Georgia's Best
3/24/2008 - MMM Leads Atlanta Firms in Private Equity Deals in 2007
Service Areas
Benefits & Compensation
Corporate
Fund Formation
Mergers & Acquisitions
Real Estate Capital Markets
Tax
Wealth Planning
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