Ivan Mitev

Ivan Mitev advises clients on the tax aspects of mergers and acquisitions, joint ventures, private equity and hedge funds, cross-border investments, and real estate investments, with a subspecialty in partnership and international taxation.

Ivan also helps family offices and high-net-worth individuals with resolving tax issues in estate planning, white-collar investigations and IRS audits. In the course of his work, Ivan drafts and negotiates partnership and LLC agreements, private placement memoranda, and various other M&A documents, including tax related opinions. In addition, he prepares IRS Appeals protests and other tax controversy documents.

Representative Experience

Advised a virtual reality venture with foreign investors on U.S. inbound tax structure.
Advised the private equity group of a Wall Street investment bank on the tax aspects of the acquisition of an interest in a joint venture between several sports teams for the provision of sports related services and concessions.
Represented the investment funds of prominent U.S. hedge fund and private equity managers in various seeding deals, including controversies surrounding exits of such deals and preservation of capacity rights.

Advised gambling operators on the availability of foreign tax credits for gaming taxes.

Advised U.S. developers on the tax aspects of litigation settlements.

Advised owners and heirs of multinational businesses on U.S. tax residency and income tax issues.

Professional Highlights

Recognized by The Legal 500 U.S., U.S. Taxes: Non-Contentious (2019).
Author of The Private Equity and Venture Capital Tax Manual, one of the few books that is exclusively devoted to the taxation of the investment fund industry.
Authored Drafting Tax Provisions for Private M&A and Investment Funds for Wolters Kluwer, which analyzes and provides examples of the tax provisions in many contemporary M&A documents.
Founder of fund-taxation.com, one of the few websites that are dedicated to the taxation of the investment fund industry.

Articles and Selected Publications

Drafting Partnership and LLC Agreements: Tax Boilerplate, Allocation, and Liquidation Provisions, Matthew Bender, January 2011. Co-author.

"Acquisition of a Foreign Target by a U.S. Public Company: Using a 'Blown B' Structure," Tax Notes, March 2013.

"FATCA’s Application to Investment Funds," LexisNexis, podcast, 2011.

"Guide to Corporate Blockers," The Tax Adviser, October 2011. Co-author.

"Tax Challenges Emerging in H.R. 4213 Carried Interest Provisions," LexisNexis, May 2010. Co-author.

"Tax Smart Techniques for Russian Citizens," Tax Notes International, August 2006. Co-author.

"And Down the Stretch They Come: An Agreed-On Carried Interest Provision Emerges as Congress Moves to a Vote on Extenders," LexisNexis, May 2010.

"The Uncertain Repeal of the Straddle Stock Exception," Tax Notes, December 2005. Contributor.

"Protective Filings for Hedge Funds After the Jobs Act," Tax Notes, November, 2005. Contributor.

Speaking Engagements
- Investing in Advanced Nuclear Energy: Meeting Clean Energy Needs Across the Economy, March 30, 2023
- Presenter, “Tax Treatment of Airplane Purchases: Maximizing Deductions for Business Aircraft Expenditures,” Strafford Webinar, June 2, 2022
- Presenter, “The Impact of IRC 1061 and Related Regulations on Profits Interests,” Practical Tax Strategies for Real Estate Deal Structuring and Implementation, April 30, 2021

Education

LL.M., University of Miami School of Law, 2005

J.D., University of Miami School of Law, 2007

Admissions

Florida

New York

Languages

Russian

Bulgarian

Areas of Focus

Practices

Representative Experience

Professional Highlights

Ivan's Insights