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Overview

Rey is a tax transactional and controversy attorney who supports clients’ tax needs, from corporate deals to private wealth to litigation.

Rey advises clients on tax matters on a variety of U.S. and international business transactions, including mergers, acquisitions, spin-offs, reorganizations, joint ventures, and estate planning for high-net-worth families. Additionally, Rey represents clients on all aspects of U.S. federal tax controversy, including government investigations, audits, administrative appeals, and litigation.

A former political science graduate with a passion for U.S. politics and democracy, Rey discovered a passion for tax law early on in law school. He was fascinated by the variety of legal recourse capabilities with respect to tax policy, as well as by how the discipline was embedded within each branch of the U.S. federal government, causing him to pursue a Master of Laws degree in taxation.  

Known as a resilient person who thrives on finding pragmatic solutions to complex problems, Rey works to provide value to clients by building personal relationships founded on trust, respect, and hard work.

Industry

Services

Education

  • LL.M., Georgetown University Law Center
    • Taxation (with distinction)
  • J.D., University of Miami School of Law
  • B.A., Florida International University
    • summa cum laude

Admissions

  • Florida
  • District of Columbia
  • New York

Professional Memberships and Certifications

  • American Bar Association, Tax Section
  • Federal Bar Association, Tax Section
  • Florida Bar Association, Tax Section

Languages

  • Spanish, proficient


*Renan works remotely and is licensed in Florida, practicing in Miami, FL. Contact Renan via email or phone for in-person/virtual meetings. Use the Washington, DC office address for mail/deliveries only.
Experience
  • Represented clients with respect to the tax aspects of corporate transactions, including domestic and cross-border mergers and acquisitions, spinoffs, and restructurings.
  • Conducted extensive legal research of statutes, regulations, legislative and regulatory history, governmental rulings and releases, case law, and third-party commentary with respect to U.S. federal and international tax issues affecting corporate transactions.
  • Drafted and prepared structure memorandums that detail the transaction steps required to implement proposed transactions in a manner that will achieve tax compliance.
  • Drafted and prepared tax opinions and IRS ruling requests on behalf of clients, such as private letter rulings and internal memoranda in connection with U.S. federal tax issues affecting sophisticated corporate transactions.
  • Negotiated and drafted tax-related provisions of each transaction agreement, based on a clear understanding of the desired structure and the client's objectives.
  • Advised on tax implications for:
    • Brookfield Asset Management Inc. (n/k/a Brookfield Corporation) in connection with the spin-off of a 25% interest in its asset management business through a newly listed company, Brookfield Asset Management Ltd., with a market value of more than $50 billion as of the spin-off date.
    • MSP Recovery, LLC in its $32.6 billion business combination with Lionheart Acquisition Corp. II.
    • Aman Group S.a.r.l. in its sale of a $900 million minority stake to Cain International and the Public Investment Fund, in a transaction that valued Aman at $3 billion.
    • AltC Acquisition Corp., a SPAC sponsored by AltC Sponsor LLC (an affiliate of M. Klein and Company, LLC), in its $850 million business combination with Oklo Inc as of the agreement date.
    • Fidelity National Financial, Inc. in an $800 million senior unsecured revolving facility.
    • F&G Annuities & Life, Inc. in a $550 million unsecured revolving facility and in a $750 million unsecured revolving facility.
    • Goldman Sachs in the sale of its Personal Financial Management unit to wealth management firm Creative Planning.
    • BCI, in the sale of its interest, alongside ATL and Audax, of Pilot Freight Services LLC to AP Moller – Maersk A/S.
Outside the Office

A Floridian, Rey loves to fish, especially in the Florida Keys. He enjoys sporting activities, golf, and time with family.

Rey is also a cigar connoisseur who likes building his cigar collection.

Community Leadership

Rey prioritizes pro bono work and has assisted nonprofits with their establishment and tax-exempt status. He has also provided pro bono tax assistance to underserved and underrepresented individuals in his local community through Legal Services of Greater Miami.