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

• Director of Tax Section, 1990-1992
• Chair of Tax Section, 1992-1993

• Member, Taxation Section

• 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