Mr. Polster advises on partnership transactions, mergers and acquisitions, initial public offerings, real estate investment trusts (REITs), regulated investment companies (RICs), outbound investment in foreign jurisdictions, Section 1031 exchanges, foreign investments in the United States including under the Foreign Investment Real Property Tax Act (FIRPTA), restructurings in and out of bankruptcy, leveraged leases, project financings and financial products.
Mr. Polster has represented clients in various tax-free and taxable acquisitions, dispositions, financings, restructurings and international tax matters. He has advised private equity funds and hedge funds in connection with fund formations and restructurings and foreign governments in connection with investments in the United States. He has worked on developing innovative leasing structures, including transactions involving Section 467 structures, foreign sales corporations, like-kind exchanges, complex debt structures and novel asset types.
In addition, Mr. Polster has advised clients on tax controversy matters involving, foreign investment in the United States, leasing, tax shelters and other transactions. He has represented clients before the Internal Revenue Service (IRS) and the U.S. Department of Treasury in connection with the negotiation of income tax treaties and the development of guidance relating to leasing matters.
Mr. Polster also has helped clients obtain private letter rulings from the IRS, including a private letter ruling for Baxter International Inc. with respect to its tax-free spin-off of Edwards Lifesciences Corporation and for a large multinational company in connection with the reorganization of its U.S. operations.
Some of the clients Mr. Polster has advised include Aircastle, Inc.; Ameritech Corporation; AutoNation, Inc.; Banc One Capital Corporation; The Bank of New York; Brookdale Senior Living Inc.; Canadian Pacific Limited; Citigroup Inc.; Covanta Holding Corporation; D.E. Shaw & Co., LLC; Douglas Emmett, Inc.; Duquesne Light Company; Essex Property Trust, Inc.; Eurocastle Investment Limited; Fortress Investment Group LLC; Global Signal, Inc.; HCP, Inc.; InvenTrust Properties Corp.; Mirant Corporation; Navistar International Corporation; New Residential Investment Corp.; New Senior Investment Corp.; Occidental Petroleum Corporation; PSEG Resources Inc.; Queensland Investment Corporation; Silver Creek Capital Management; SL Green Realty Corp; SmileDirectClub, Inc.; UDR, Inc.; US Airways Group, Inc.; Westfield America, Inc.; and Windstream Holdings.
Mr. Polster has been repeatedly selected for inclusion in Chambers Global, Chambers USA, Expert Guides’ Guide to the World’s Leading Tax Advisers and The Best Lawyers in America. He also has been named to ITR World Tax and was previously named a Law360 Tax MVP.