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Howard J. Barnet, Jr.

Howard J. Barnet, Jr.

Partner
Chair, Tax Department; Member, Hiring Committee

Wall Street Office
2 Wall Street
New York, NY 10005
barnet@clm.com
phone: 212-238-8606
fax: 212-732-3232 download v-card

Practice Areas

Canada Cross-Border, Tax, Commercial Lending, Tax-Exempt Organizations, Tax-Exempt Organizations Real Estate

Practice Description

Tax, including international, corporate and partnership federal income tax matters, as well as New York State matters.

Education

  • A.B., 1976 Oberlin College
  • J.D., 1979 Yale Law School 
  • LL.M., 1983 New York University School of Law (in Taxation)

Admissions

  • 1980 New York
  • 1993 U.S. Tax Court

Affiliations

  • American Bar Association, Tax Section
  • New York State Bar Association, Tax Section
  • The Tax Club of New York City

Publications Available on this website...

"No Time Like the Present to Consider a Roth IRA," Client Advisory, February 22, 2010; "New Tax Law Encourages Immediate Relief to Haiti," Client Advisory, January 26, 2010; "Final Rules on Electronic Annual Return for Small Tax-Exempt Organizations," Client Advisory, August 14, 2009; "I.R.S. Suggests Foreign Bank Account Reporting Requirements May Apply to Interests in Offshore Hedge Funds," Client Advisory, June 25, 2009; "Voluntary Disclosure of Offshore Accounts," Client Advisory, March 27, 2009; "For Offshore Fund Managers, It’s Time to Rethink Everything," Client Advisory, March 25, 2009; "Madoff Securities Task Force Update: IRS Issues Helpful Guidance," Client Advisory, March 18, 2009; "Madoff Securities Task Force Update: Claiming Tax Benefits for Losses," Client Advisory, January 9, 2009; "Madoff Securities Task Force Update: March 4, 2009 Deadline," Client Advisory, January 8, 2009; "Madoff Securities Task Force," Client Advisory, December 30, 2008; "Last Call for 409A Amendments to Deferred Compensation Arrangements," Client Advisory, December 8, 2008; "U.S. Tax and Securities Law Considerations in Canadian Income Trust Conversions," Client Advisory, November 24, 2008; "The Emergency Economic Stabilization Act of 2008--Tax Provisions," Client Advisory, October 6, 2008; "Code Section 409A: Limited Relief From Documentary Compliance this Year," Client Advisory, November 5, 2007; "IRS National Office Rules Adversely on Variable Prepaid Forward Contracts with Securities Loan," Journal of Taxation and Regulation of Financial Institutions, August 2006

Additional Publications

“The Application of the Unrelated Business Tax to Securities and Tax-Exempt Organizations,” Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings, 2007 (PLI); “IRS Reiterates Stand On Variable Prepaid Forward Contracts,” Journal of Taxation and Regulation of Financial Institutions, May/June 2007; “The Application of the Unrelated Business Tax to Securities and Tax-Exempt Organizations,” Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings, 2006 (PLI); “IRS National Office Rules Adversely on Variable Prepaid Forward Contracts with Securities Loan,” Journal of Taxation and Regulation of Financial Institutions, July/August 2006; “Corporate Taxpayers Win Rulings That Validate Shelters,” The New York Law Journal, May 16, 2002; “Halle v. Commissioner: The Tax Treatment of Preclosing Interest,” Tax Notes, August 5, 1996.

Presentations

“U.S. Federal Taxation of Investment Products Held by Non-U.S. Persons,” with Jane Tse, Practising Law Institute, June 3, 2008; “Selected Tax Aspects of Exchange Traded Funds,” Maximizing Market Returns with ETFs Conference, Miami, February 26, 2006; “Tax Issues Relating to Accidental Ownership of Off-Shore Companies by U.S. Persons” Practising Law Institute, June 8, 2005; “Need-to-Know Tax Aspects--Structuring an Acquisition or Sale of a Privately Held Business,” The Investigative Services and Security Industry M&A Forum, April 28, 1998

Significant Cases

Representation of large pharmaceutical company in joint venture and acquisitions. Tax advice Cases: in numerous other significant M&A transactions, joint ventures and financings. Extensive experience in the area of investment funds, including mutual funds. Practice has also included obtaining novel IRS private rulings and several substantial federal tax controversies at the IRS Appeals Office level.