Davies | Abraham Leitner

Taxation

Representative Work

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Foreign Activities of U.S. Taxpayers Committee of the Tax Section of the American Bar Association
The Inbound U.S. Activities of Foreign Taxpayers and the Outbound Foreign Activities of U.S. Taxpayers Committees of the Tax Section of the New York State Bar Association
International Fiscal Association

Article: New Regulations Tighten Anti-Inversion Rules but Probably Won't Stop U.S. Corporate Expatriation

Selected Thoughts on the Pending Protocol to the U.S.-Canada Income Tax Treaty

Selected US Tax Developments - New Canada-US Protocol Contains Hybrid Entity Surprises

Publication - Canada-U.S. Investment: Canadian Tax Perspective. How the New Canada-U.S. Treaty Protocol Affects Business Enterprises.

IRS Announces That Certain Distributions by U.S. REITs to Foreign Investors Will Be Taxable

New York State, 1996

New York University, LL.M. (Taxation), 2000
Columbia University, J.D. (Harlan Fiske Stone Scholar), 1996
Touro College, B.S. (summa cum laude), 1992

Abe Leitner is a partner in the Taxation practice in the New York office. He has planned numerous cross-border transactions for U.S. and foreign individuals and corporations. He has structured international joint ventures involving real estate investments in the United States and abroad and has advised multinational corporations on cross-border mergers and acquisitions. Abe has advised insurance companies, hedge funds, real estate developers, REITs, assisted living providers, manufacturers and high net worth individuals.

Representative Work

Acted for H&R REIT in connection with its novel restructuring into a stapled finance trust structure.
Acted for Atlas Holdings and Blue Wolf Capital Management in connection with their acquisition of Neenah Paper's pulp mill in Pictou, Nova Scotia.
Acted for Cadbridge in connection with the $2.5 billion acquisition of Legacy REIT.
Acted for MDC North America in connection with the formation of a U.S. real estate fund.
Acted for ClearOne Communications in connection with its acquisition of HaiVision Systems.

Articles and Publications

Abe has written numerous articles and speaks frequently on current topics in international tax. He served as an Editor of the Journal of Taxation and has written numerous articles for the Journal. Abe has also written articles for the Journal of Taxation of Global Transactions, the Metropolitan Corporate Counsel, and Tax Notes. Some of his articles include, "Selected Thoughts on the Pending Protocol to the U.S.-Canada Income Tax Treaty" and "Selected U.S. Tax Developments - New Canada-U.S. Protocol Contains Hybrid Entity Surprises".

While at Columbia, Abe was an editor of the Columbia Business Law Review.

Speaking Engagements

Abe was a panel member of the Annual Conference of the USA Branch of the International Fiscal Association addressing the U.S. Model Treaty approach to hybrid entities. He was part of the panel at the Joint Meeting of the United States and Canada branches of the International Fiscal Association, addressing U.S.-Canada Cross Border Financing Structures. Abe was a member of the American Bar Association panel addressing the "Use of Derivatives to Avoid U.S. Taxation of Effectively Connected Income".

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