Sonya Jindal Tork

Representative Experience

Tax, Real Estate, Business Succession, and Estate Planning

• Advise clients on tax and non-tax business structuring issues in connection with partnership, S-corporation, real estate, international and business succession transactions and matters.
• Advise real estate developers, investors and beneficiaries of estates in structuring tax-advantaged transactions, including tax-deferred exchanges under Sections 1031 and 1033, qualified conservation easements, historic preservation matters, and qualified opportunity zone investments.
• Advise and draft tax opinions on behalf of developers and nonprofits in connection with new market tax credits, historic preservation tax credits, and low-income housing tax credits.
• Advise on wealth transfer planning for individuals and families, including implementation of sophisticated wealth transfer techniques, such as transferring of interests in family-owned entities and charitable gifts of S-Corporation stock.
• Advise family-owned businesses in succession planning and related estate planning issues.
• Advise corporate executives and businesses on structuring equity and incentive plans and award agreements.

Tax Controversy and Civil and Criminal Tax Investigations

• Represented a senior level partner at a major accounting firm indicted for violations of federal tax law. Following a five-week jury trial in January 2013, the partner was acquitted of all charges.
• Represented partnership before U.S. Tax Court and IRS Appeals in connection with IRS’s challenge of partnership transaction that generated more than $173 million in deductions and $1.3 billion in losses and obtained extremely favorable settlement for client.
• Represented individuals with undisclosed foreign financial accounts and handle IRS voluntary disclosures, civil audits, and criminal investigations with respect to such offshore matters.
• Represents clients at all stages of civil and criminal tax matters, including investigations, pleading, sentencing, settlement, and appeals stages.
• Represents clients in government examinations of complex tax shelters and other tax-advantaged strategies.

Nonprofit and Tax-Exempt Organizations

• Represents nonprofit and tax-exempt organizations and foundations in all aspects of their organization and operation, including formation, governance, mergers and restructurings, unrelated business income tax matters, intermediate sanctions, joint ventures, endowment funds, fundraising, charitable giving and planned giving programs, and compliance with state law charity registration requirements.
• Represents hospital systems and health care entities in connection with restructurings, joint ventures with for-profit entities, acquisitions of for-profit entities, conversion of for-profit entities to non-profit, unrelated business income tax issues, and supporting organization issues.
• Advise family and corporate private foundations with respect to private foundation tax law restrictions and limitations related to self-dealing, excess business holding, taxable expenditures, program-related investments, and minimum distribution requirements.
• Represents nonprofit organizations and executives in audits and investigations before the IRS and the Ohio Attorney General’s Office.
• Represents nonprofit organizations in connection with obtaining and maintaining bingo licenses.