Jessica Millett is a partner in Duval & Stachenfeld’s Tax Practice Group. She has particular expertise in the U.S. tax issues that arise in cross-border real estate transactions, although her practice includes advising on both domestic and international matters across a number of industries. She regularly advises clients on tax structuring and documentation for real estate acquisitions, joint ventures, restructurings and refinancing arrangements, including inbound and outbound investments, and structures involving REITs.
Mrs. Millett’s practice also includes advising on tax-efficient structures for cross-border finance transactions, including U.S. and international securities offerings (debt and equity), private placements and private equity transactions. She regularly represents sponsors and managers of, and institutional investors in, private investment funds including real estate, distressed debt, and hedge funds. Mrs. Millett also has extensive experience advising financial institutions on a variety of tax and compliance issues including U.S. withholding and information reporting rules, tax treaty planning, and the Foreign Account Tax Compliance Act.
Mrs. Millett’s recent, notable transactions include advising:
a sovereign wealth fund on a Section 892 compliant investment for a mixed use redevelopment project including luxury apartments, retail space, a parking garage and office space;
a US-based investment advisor on structuring distressed debt acquisitions and foreclosures for non-US investors;
a real estate fund with non-US investors on establishing a mortgage loan origination platform;
a US-based private equity real estate company on a $75 million recapitalization of a Latin American investment;
a publicly traded REIT on a EUR 50 million joint venture with a European real estate investment manager; and
an Italian fund of funds in numerous investments in US real estate funds.
Mrs. Millett is Chair of the Subcommittee for Foreign Investors of the ABA Tax Section Real Estate Committee
She also serves as Chair of the Firm’s Pro Bono Committee having initiated pro bono relationships with several organizations to assist clients in U-Visa applications and asylum applications.
Prior to joining the Firm in 2012, Mrs. Millett was an associate at Linklaters LLP where she practiced since 2006. Mrs. Millett received her B.A. from Johns Hopkins University in 2000, and her J.D. and LL.M. (International and Comparative Law) from Duke University School of Law in 2006, where she was a member of the Duke Journal of Comparative and International Law. Mrs. Millett is admitted to practice in New York.
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