Peter S.Liu

Associate

Chicago + 1.312.269.1533

Peter Liu advises clients on the federal income tax aspects of real estate transactions, real estate investment trusts (REITS), private equity fund formations, partnership structures, acquisitions, and dispositions.

Peter counsels real estate investment funds, sovereign investors, pension funds, and other tax-exempt investors with respect to their U.S. investments. Peter helps clients navigate issues concerning ECI (effectively connected income), UBTI (unrelated business taxable income), '40 Act (investment company act), and FIRPTA (Foreign Investment in Real Property Tax Act). Peter regularly works with clients such as Greystar Real Estate Partners, Mill Creek Residential Trust, Pantheon Ventures, and LaSalle Investment Management on domestic and cross-border transactions.

Peter's experience also includes tax controversy matters, with a particular focus on transfer pricing disputes involving technology, pharmaceutical, and health care companies. He has advised clients in all stages of tax litigation, from audit and administrative appeals before the Internal Revenue Service (IRS) to litigation before the U.S. Tax Court and other federal courts.

Experience

  • Global secondaries manager purchases portfolio of private equity fund interests from institutional asset managerJones Day represented global secondaries manager in connection with the purchase of a portfolio of private equity fund interests from an institutional asset manager.
  • Gilde Healthcare VI raises €740 millionJones Day represented Gilde Healthcare in connection with the establishment of Gilde Healthcare Venture & Growth VI with €740 million in commitments.
  • LaSalle completes $510 million joint venture with UDRJones Day represented LaSalle Investment Management in its $510 million joint venture with UDR, Inc. (NYSE: UDR) to create a portfolio of core multifamily assets in key markets across the U.S.
  • Bally's transfers real property assets of two properties to Gaming And Leisure Properties for $635 millionJones Day advised Bally's Corporation on the completion of the previously announced transfer of the real property assets of Bally's Tiverton Casino & Hotel in Tiverton, RI and Bally’s Hard Rock Hotel & Casino Biloxi in Biloxi, MS to GLP Capital, L.P., the operating partnership of Gaming and Leisure Properties, Inc., for $635 million in total consideration, inclusive of $15 million in the form of OP units. Bally's leased back both properties and continues to own, control, and manage all the gaming operations of the facilities on an uninterrupted basis.
  • DataBank converts to a REIT and recapitalizes to bring in new investorsJones Day advised DataBank as special tax counsel in connection with its conversion to a real estate investment trust (REIT) and a complex recapitalization of its capital structure to bring in new investors.