Michael A. Lehmann, Esq. advises tax-exempt organizations on a wide variety of global tax matters. He has extensive experience representing nonprofit organizations, including healthcare providers, social services agencies, alcohol and substance abuse centers, scientific research organizations, religious organizations, museums, trade associations, private foundations, as well as arts, community development and social welfare organizations. Mr. Lehmann counsels clients on obtaining and maintaining federal, state and local tax-exemption; obtaining real property tax exemption; executive compensation; joint ventures and partnerships between non-profit and for-profit organizations; employee benefits; tax disputes, audits, controversies and protests involving the Internal Revenue Service, the New York State Department of Taxation and Finance and the New York City Department of Finance.
In particular, Mr. Lehmann has significant experience advising clients on UBIT, ECI and FIRPTA issues, having handled such issues in transactions, planning and tax strategies as well as audits and controversies with the IRS. He has obtained favorable rulings on UBIT structures and has successfully defended the non-UBIT characterization of transactions in more than a dozen IRS audits. He is a regular columnist for The Journal of Exempt Organizations and has published numerous articles relating to UBIT topics.
Mr. Lehmann has also represented many non-U.S. persons in handling ECI exposures in a variety of contexts including all types of investment funds, real estate projects, blocker structures, tax treaty planning, energy and power generation projects, and more. He has successfully represented numerous non-U.S. investors in IRS audits of asserted FIRTPA and ECI generating activity, closing nearly all such audits with either no change letters or very favorable settlements.
Prior to joining Dechert, Mr. Lehmann worked at another law firm where he served as the partner in charge of the tax and tax-exempt organizations practice.