Allison M. Stelter

Allison focuses her practice on federal income tax issues related to structured finance and securitization, equity REITs and mortgage REITs, including capital markets transactions, mergers and acquisitions, and joint ventures, and the taxation of partnerships and other pass-through entities.

Allison represents issuers and underwriters concerning federal tax issues in private and public securitized REMIC, debt, and grantor trust offerings, in connection with a variety of assets including real estate, forward and reverse performing, reperforming, and nonperforming mortgage loans, online marketplace loans, merchant cash advances, auto loans and other financial assets. She counsels REITs on securities offerings, acquisition transactions including tax protection agreements, roll-up transactions and UPREIT structures, initial public offerings, investment structuring, taxable REIT subsidiary structures, mezzanine loans and distressed debt. She also represents REITs in securitized debt transactions, merger and acquisition transactions, reorganizations and subsidiary spin-offs. Allison also has served as an adjunct professor teaching Partnership Taxation at Michigan State University College of Law.

Relevant Experience

  • Represented various parties in connection with the federal tax aspects of purchases, sales, financing and securitizations of forward and reverse performing, reperforming and nonperforming mortgage loans, REO, online marketplace loans, auto loans, credit card receivables and other financial assets.
  • Represented issuers and underwriters concerning tax issues in private and public mortgage-backed and asset-backed security offerings, including the representation of US government agencies and government sponsored enterprises in mortgage loan securitization transactions.
  • Tax structuring and evaluation of various securitization, resecuritization, debt, and grantor trust transactions, including issues regarding real estate assets, distressed assets and US withholding.
  • Represented issuers and lenders concerning tax issues in financing of servicer advance receivables.
  • Represented issuers and underwriters in mortgage loan credit risk transfer securities issuances.
  • Represented issuers and underwriters in initial public offerings of equity and mortgage REITs.
  • Represented issuers and underwriters in connection with public and private equity and debt offerings by REITs, including REITs investing in mortgage-backed securities, mortgage loans, hotels, commercial office buildings, retail properties, industrial properties, farmland and single family rental (SFR).
  • Advised partnerships and contributors regarding partnership roll-up transactions and tax protection agreements.
  • Represented REIT clients in connection with securitized debt transactions.
  • Counseled clients generally on the federal income tax aspects of restructurings and debt workouts.

Memberships

  • Member, American Bar Association, Section of Taxation
  • Council Member, State Bar of Michigan, Tax Section
  • Member, National Association of Real Estate Investment Trusts (NAREIT)

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