Zion Levi

I am an experienced tax, business transactions and real estate attorney and seasoned legal advisor to domestic and international businesses and business owners. 

My tax practice encompasses all facets of federal income tax law and related state income taxation, with a particular focus on tax controversies, optimal tax planning and international taxation. I have substantial expertise in representing clients during IRS audits and other examinations, at the IRS Office of Appeals, the IRS Advance Pricing Mutual Agreement (APMA) Program, the IRS Criminal Investigation Division (CID), and  the United States Tax Court. I regularly counsel clients on matters such as cryptocurrency, permanent establishments, methods of accounting, transfer pricing, financial products, voluntary disclosures, like-kind exchange under IRC 1031, branch profit tax, intercompany transactions, tax free mergers, acquisitions and other reorganizations (M&A), consolidated tax returns, hybrid structures, foreign tax credits, tax treaties, controlled foreign corporations (CFCs), passive foreign investment companies (PFICs), Foreign Derived Intangible Income (FDII), Global Intangible Low-Tax Income (GILTI) and Base Erosion and Anti-Abuse Tax (BEAT). 

In the area of business transactions, my acumen proves highly valuable when strategizing efficient acquisition structures, in negotiating complex mergers and other business combinations, in obtaining favorable Private Letter Rulings (PLRs), and in securing Advance Pricing Agreements (APAs) and competent authority relief. I regularly counsel on matters such as tax free combinations and reorganizations, transfer of intangibles, allocation of purchase price, noncompete arrangments, personal goodwill, licensing and foreign exchange (FX) issues. I served as counsel on numerous business acquisitions ranging in size from $500 thousand to more than $500 million.

In the area of real estate, I have extensive experience in a wide range of commercial real estate transactions, including the acquisitions and dispositions of commercial buildings, like-kind exchange under IRC 1031, Real Estate Investment Trusts (REITs), tenancy in common (TIC), commercial leases, ground leases, joint ventures, and permanent and mezzanine financing. I have served as lead negotiator on multiple acquisitions and dispositions of commercial buildings of all classes, and have authored tax opinions in the area of like-kind exchange under IRC 1031.

I draw upon more than 24 years of legal experience in representing clients in virtually every domestic and international industry vertical. I am a contributor national expert to the Bureau of National Affairs (BNA), a frequent speaker and panelist in CLE programs, including programs produced and sponsored by the American Bar Association (ABA), had published extensively in respected industry and professional publications, and have had my work cited in authoritative legal treatises.