Morris Manning & Martin, LLP

Aresh Homayoun

Aresh Homayoun

Partner
Phone: 202.971.4227
Fax: 202.408.5146
[email protected]

Aresh Homayoun is a Partner in the Tax and Real Estate Capital Markets groups. Mr. Homayoun’s practice focuses on federal income taxation issues for business, including the tax aspects of real estate investment trusts and their operating partnerships, regulated investment companies, corporate taxation and taxation of flow through entities.  He also represents taxpayers in tax controversy work and IRS practice and procedure matters. 

Prior to joining Morris Manning & Martin, Mr. Homayoun was in house tax counsel at a Fortune 50 company and, prior to that engagement, worked as a tax associate at a large international law firm.

Mr. Homayoun also served as a judicial law clerk for the Honorable Andrew L. Sonner of the Court of Special Appeals of Maryland.

Representative Experience

  • Represent fund in connection with all federal income tax matters related to the sale of stock in three private REITs for a sales price of more than $950 million
  • Represent public non-listed REIT in connection with all federal income tax matters related to joint venture with private equity fund
  • Prepare comprehensive tax opinions on various REIT-related tax matters, including application of preferential dividend rule to a multi-class stock structure
  • Prepare and negotiate pre-filing agreement with IRS to claim a $2.5 billion bad debt deduction
  • Represent creditors with respect to all federal income tax matters relating to bankruptcy of Washington Mutual, Inc., including negotiations over ownership of tax refunds and application of consolidated Section 382 rules
  • Represent investors with respect to all federal income tax matters relating to $4 billion acquisition of a hotel REIT
  • Prepare and negotiate private letter ruling requests on various tax matters, including application of REIT income and asset tests and S corporation qualification matters

Accolades

  • Listed, Legal 500, Real Estate Investment Trusts (REITs), 2018