Samuel P. Grilli
Sam focuses his practice on federal income tax planning related to domestic and cross-border transactions. Sam advises clients on structuring partnerships and joint ventures, mergers and acquisitions, reorganizations, capital markets transactions, private letter rulings, real estate transactions, fund and real estate investment trust (REIT) structures and cross-border business or investment in the US.
Sam is experienced in tax matters related to professional sports teams, complex partnership transactions, REITs, sovereign wealth and pension funds, structured finance transactions, membership deposits, like-kind exchanges, and multinational clients investing or doing business in the US, especially with regard to inbound investments in US real estate involving the Foreign Investment in Real Property Tax Act (FIRPTA), treaty and other related issues. In addition, Sam is well experienced in advising, negotiating and drafting partnership and joint venture agreements, purchase-sale agreements and other related transactional agreements. Sam has served as chair of, and spoken at, the Firm’s training concerning partnership taxation held in coordination with the Chicago Chapter of the Tax Executives Institute (TEI).
Professional Associations and Memberships
- American Bar Association - Member, Section of Taxation
- National Association of Real Estate Investment Trusts (NAREIT) - Member
- Illinois~United States (2011)
- University of Chicago Law School (2011)
- Cornell University (2004)
- Co-author, "Taxation of Player Contract Trades-The IRS Reaches the Correct Result," Journal of Taxation, August 2019
- Author, "Do Taxpayers Still Need to Sell Domestically Controlled REIT Shares to Avoid FIRPTA?" Journal of Taxation, May 2019
- Co-author, "The 'State of the Art' in Like-Kind Exchanges-2019," Journal of Taxation, February 2019
- Co-author, "New Regulations on Partnership Debt and Disguised Sales: Is the Road to Hell Paved with Good Intentions? (Part 2)," Journal of Taxation, March 2017
- Co-author, "New Regulations on Partnership Debt and Disguised Sales: Is the Road to Hell Paved with Good Intentions? (Part 1)," Journal of Taxation, February 2017