People > Attorney > Ingolf Noto
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Overview
Ingolf became a partner with the firm in 1985. His practice emphasized federal, state and international taxation. A considerable amount of his practice was in the area of corporate mergers, acquisitions and reorganizations. Ingolf gained extensive experience by representing clients involved in controversies with the Internal Revenue Service.
In 2010, Ingolf was one of two lead tax attorneys for the Chief Restructuring Officer in the Sunwest Management transaction, a $1.2 billion asset sale involving more than 140 senior living properties located in 39 states. The case involved an SEC receivership proceeding and the related bankruptcy of an enterprise that was owned by hundreds of tenants-in-common and limited liability companies. Ingolf negotiated and resolved significant tax and business issues which allowed the investors to substantially limit their tax liability in the transaction.
On another representative transaction, Ingolf was responsible for recapitalizing and restructuring an affiliate group of corporations to qualify the corporate group to elect S-corporation status. This project involved comprehensive planning and drafting relating to shareholder agreements and various stock/phantom stock plans and the development of alternative stock valuation formulas.
Ingolf also led negotiations with the tax authorities of a foreign country which resulted in the client obtaining a tax accord pursuant to which it received substantial tax benefits not available under the tax statutes of the foreign jurisdiction or the applicable treaty.
Ingolf has been recognized as a leading attorney in tax law by The Best Lawyers of America®. He was also listed in Chambers USA America's Leading Lawyers for Business.
Ingolf is Honorary Consul of Denmark for the State of Oregon, and is fluent in Danish.
In 2010, Ingolf was one of two lead tax attorneys for the Chief Restructuring Officer in the Sunwest Management transaction, a $1.2 billion asset sale involving more than 140 senior living properties located in 39 states. The case involved an SEC receivership proceeding and the related bankruptcy of an enterprise that was owned by hundreds of tenants-in-common and limited liability companies. Ingolf negotiated and resolved significant tax and business issues which allowed the investors to substantially limit their tax liability in the transaction.
On another representative transaction, Ingolf was responsible for recapitalizing and restructuring an affiliate group of corporations to qualify the corporate group to elect S-corporation status. This project involved comprehensive planning and drafting relating to shareholder agreements and various stock/phantom stock plans and the development of alternative stock valuation formulas.
Ingolf also led negotiations with the tax authorities of a foreign country which resulted in the client obtaining a tax accord pursuant to which it received substantial tax benefits not available under the tax statutes of the foreign jurisdiction or the applicable treaty.
Ingolf has been recognized as a leading attorney in tax law by The Best Lawyers of America®. He was also listed in Chambers USA America's Leading Lawyers for Business.
Ingolf is Honorary Consul of Denmark for the State of Oregon, and is fluent in Danish.
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