Monica Gianni

Monica Gianni resolves federal tax law issues. She advises clients on tax matters related to the formation, operation and reorganization of business entities; represents tax-exempt organizations such as public charities, private foundations, social clubs, homeowners' associations, business leagues and social welfare organizations; and addresses legal and tax issues with U.S. clients doing business in foreign countries and foreign investors entering the U.S. market. Monica represents clients in IRS tax audits and foreign bank account voluntary disclosures. She is a frequent speaker on subjects related to international tax, tax-exempt organizations, limited liability companies, and corporate taxation, and has been an adjunct professor of international taxation at the University of Washington and entity taxation at Seattle University.

Practice Highlights

• Tax advice on passive foreign investment company and other international tax issues to Energy Metals Corp., Sierra Wireless, Unbridled Energy Corp., Canfor Pulp Products Inc., and Staccato Gold Resources Ltd., Canadian companies
• Tax planning for acquisition of Little Red Services, a closely held company, including S corporation and partnership tax issues
• Like-kind exchange tax planning for spectrum for Clearwire, including preparation of private letter ruling and meeting with IRS national office
• Tax advice and drafting of partnership agreement for investment fund involving U.S. and Canadian investors
• Tax advice on cancellation of indebtedness income and tax rules for cooperatives for Associated Grocers
• Negotiated sale of mortgage company in difficult economic environment
• Tax exemption opinions for bond financings of Children's Hospital, Legacy Health Systems, Virginia Mason Hospital, Whitman College, Verdugo Hills Hospital, Citrus Valley Medical Center, Overlake School, and University of Western States
• Reorganization of Flynn Industries, through mergers of limited liability companies and liquidations of corporations
• Obtained state property tax exemption for organization involved in demonstration farm
• Representation of U.S. fishing company in IRS tax audit