Nancy Collins

Representative Experience

• Represented regional health care system on tax, corporate and health care matters in the sale of substantially all its assets, including a network of 9 hospitals, 39 clinics, 2 inpatient facilities, 13 regional rehabilitation facilities, physician clinics, 2 emergency centers, regional home health services covering 41 counties, a comprehensive trauma center network, and an EMS fleet of more than 45 ambulances and 4 helicopters. *
• Advised a master limited partnership on formation-structuring techniques that reduce adverse tax consequences applicable to the fund manager as well as the equity investors, including foreign investors and tax-exempt organizations that are UBTI sensitive.  *
• Counsel private equity funds on compliance with tax withholding regimes applicable to foreign investors, tax withholding rates under the Internal Revenue Code and tax treaties, FATCA withholding, and FIRPTA withholding on US real property interests. *
• Advised a real estate limited liability company on various state and local tax issues relating to transfer of oil and gas assets, including corporate income and franchise taxes, allocation and apportionment issues, property taxes, sales and use taxes, utility user taxes, environmental taxes, transfer taxes, and other excise taxes.  *
• Advised a charitable organization on the formation of a nonprofit corporation and obtaining tax-exempt status under Section 501(c)(3). Also advised on the federal income tax issues relating to the operation of the charitable organization, including unrelated business taxable income, compliance and reporting issues, investments, governance, and charitable contribution deduction issues. *
• Advised clients in more than 25 real estate and oil and gas transactions involving “like-kind exchanges” under Section 1031 of the Internal Revenue Code, allowing clients to defer millions in taxable gain on the sale of real property, including forward exchanges, reverse exchanges and build-to-suit exchanges, as well as more unique exchanges such as arrangements for the distribution and purchase of undivided interests in property as tenant-in-common.  *
• Represented domestic and international clients with a variety of backgrounds, family situations and succession planning concerns in developing comprehensive estate plans.  *