Patricia Hintz

Experienced, practical tax-credit-transactions counsel

Pat Hintz practices primarily in the areas of taxation and tax-exempt organizations and counsels clients on a wide variety of federal, state and local tax matters. A licensed, certified public accountant in Wisconsin who once worked at two of the big four accounting firms, Pat has extensive experience representing clients in:

• Tax credit transactions
• Tax planning

With experience both as a practicing accountant and tax lawyer, there are few tax questions Pat has not encountered and answered. Clients appreciate her commitment to practical solutions, giving issues large and small their proper due — and doing so efficiently as well as effectively.

• Representing developers, investors and syndicators in tax credit transactions, primarily involving low-income housing, historic and new markets tax credits, as well as a full range of other federal and Wisconsin state credits.
• Advising tax-exempt organizations (including public charities and private foundations) in a wide range of areas, including formation, governance and compliance with emphasis on joint ventures between tax-exempt and for-profit entities and taxation of unrelated business income, including reporting of foreign investments and state taxation of unrelated business income.
• Advising on taxation of pass-through entities, including S corporations, partnerships and limited liability companies and the unique tax issues confronted by the owners of these entities.
• Substantial experience in providing tax opinions, with a special emphasis on opinions provided in connection with tax credit transactions.
• Planning for state and local excise, franchise, income, and sales and use tax, including nexus determinations and voluntary disclosure agreements.
• Advising on employment and income tax issues associated with employee compensation compliance and planning, and taxation of employment settlement awards.
• Making applications for private letter rulings at both the federal and state level on a wide range of topics.

• Assisted low-income housing tax credit investors and syndicators in acquiring multiple tax credit investments and provided the following services:
  • Negotiated equity documents, including partnership/operating agreements, development agreements, guaranties and purchase options.
  • Conducted due diligence to identify and quantify business and tax issues and risks.
  • Provided tax and financial analysis and recommended and evaluated transaction structuring alternatives.
  • Provided tax opinions supporting the tax treatment of the investments.
• Worked with tax credit investor to facilitate exits from low-income housing tax credit investments upon both the conclusion of the investment’s credit period and the investment’s compliance period.
• Assisted borrower in obtaining consent of lenders in NMTC financing to restructuring of borrower’s business and provided supplemental tax opinion confirming conclusions in original tax opinion.