Overview

John Grumbacher, a Director, is a member of our Tax group. He focuses his practice on the taxation of institutional real estate investments, private equity and M&A transactions, as well as general tax law.

John has extensive experience in the taxation of flow-through entities and in the structuring of complex transactions. Prior to joining Goulston & Storrs, he was New England Director of Merger & Acquisition Tax Services at Ernst & Young LLP.

In addition, John has extensive experience in the taxation of partnerships and LLCs, including special allocations, contributions of appreciated or depreciated property, avoidance of investment company status, allocations of liabilities and avoidance of gain from deemed cash distributions, technical terminations and anti-churning structures.

Representative Experience

• Representation of Sohu.com Inc. in connection with the sale of the game information portal 17173.com to Sohu’s majority-owned subsidiary Changyou.com Limited.
• Representation of a provider of innovative technology products for the military, homeland security and commercial markets in its acquisition by L-3 Communications, including a spin-out of a medical device business excluded from the transaction. 
• Analysis of various structuring alternatives for disposition of unwanted assets and step-up in basis for certain wanted assets in connection with sale of stock of private REIT for $300 million.
• Planning to avoid taxable cancellation of debt income to partners in connection with bankruptcy of New England ski resort and condominium partnership.
• Development of structural solutions to avoid UBTI to fund partners from partnership investments in operating partnerships.
• Acquisition of UK business by public, U.S. parent using financing structure permitting tax deduction of interest in both U.S. and U.K..
• Reorganization of corporation engaged in global management consulting services into a flow-through structure without triggering gain to former shareholders