Portrait of Frederick N. Widen

Frederick N. Widen

Partner

  • Serves as tax counsel and general counsel to numerous closely held businesses, real estate developers, and family offices.
  • Serves as both lead business counsel and tax counsel in mergers and acquisitions.
  • Represents clients in controversy and litigation involving federal, state, and local income, sales and property tax, and criminal tax matters.
  • Represents numerous clients in succession, trust, estate, and generation skipping tax planning.
  • Represents clients with respect to structuring 1031 exchanges involving complexities regarding variations of interests, drops and swaps, partnership divisions, related parties, and tenants in common interests.
  • Represents clients in Internal Revenue Service and state and local tax collection matters.
  • Assists clients in structuring and establishing opportunity zone funds and opportunity zone entities.
  • Representation includes representing clients as lead counsel in the U.S. Sixth Circuit, U.S. District Courts, U.S. Tax Court, Ohio Supreme Court, Ohio Board of Tax Appeals, and Ohio State Circuit Court of Appeals.
  • Assisted developers in restructuring entities to facilitate the transfer of ownership interests in developments to key employees and also implemented transfer of additional interest into a family limited partnership for the same developer.
  • Simplified the structure for ongoing operations through the use of a master limited liability company, including tracking portfolio companies and series LLCs.
  • Advised clients with respect to effect of IRC Section 382 on net operating loss carry-forwards.
  • Represented General Electric Medical Systems, Inc. in obtaining Ohio Board of Appeals ruling that diagnostic imaging equipment is exempt from sales tax as manufacturing equipment.
  • Represented numerous employee stock ownership plans (ESOPs) in the structuring of business acquisitions and dispositions.
  • Represented clients in connection with transferring of real estate to real estate investment trusts.
  • Represented health care providers in sales to public companies.
  • Represented professional corporations in the fields of medicine, dentistry, law, accounting, and psychology, among others.
  • Practiced as a Certified Public Accountant (1976-1982).

Experience

  • Serves as tax counsel and general counsel to numerous closely held businesses, real estate developers, and family offices.
  • Serves as both lead business counsel and tax counsel in mergers and acquisitions.
  • Represents clients in controversy and litigation involving federal, state, and local income, sales and property tax, and criminal tax matters.
  • Represents numerous clients in succession, trust, estate, and generation skipping tax planning.
  • Represents clients with respect to structuring 1031 exchanges involving complexities regarding variations of interests, drops and swaps, partnership divisions, related parties, and tenants in common interests.
  • Represents clients in Internal Revenue Service and state and local tax collection matters.
  • Assists clients in structuring and establishing opportunity zone funds and opportunity zone entities.
  • Representation includes representing clients as lead counsel in the U.S. Sixth Circuit, U.S. District Courts, U.S. Tax Court, Ohio Supreme Court, Ohio Board of Tax Appeals, and Ohio State Circuit Court of Appeals.
  • Assisted developers in restructuring entities to facilitate the transfer of ownership interests in developments to key employees and also implemented transfer of additional interest into a family limited partnership for the same developer.
  • Simplified the structure for ongoing operations through the use of a master limited liability company, including tracking portfolio companies and series LLCs.
  • Advised clients with respect to effect of IRC Section 382 on net operating loss carry-forwards.
  • Represented General Electric Medical Systems, Inc. in obtaining Ohio Board of Appeals ruling that diagnostic imaging equipment is exempt from sales tax as manufacturing equipment.
  • Represented numerous employee stock ownership plans (ESOPs) in the structuring of business acquisitions and dispositions.
  • Represented clients in connection with transferring of real estate to real estate investment trusts.
  • Represented health care providers in sales to public companies.
  • Represented professional corporations in the fields of medicine, dentistry, law, accounting, and psychology, among others.
  • Practiced as a Certified Public Accountant (1976-1982).