Jeffrey Scheine’s practice focuses on U.S. domestic and international tax matters for both U.S. and non-U.S. clients, with an emphasis on investments by Canadian institutional and corporate investors in the United States. In addition, a significant part of his practice consists of providing tax advice for various types of debt financing vehicles, both onshore and offshore. He represents financial, strategic and institutional buyers in the U.S. and abroad in connection with their North American and foreign acquisitions and activities. Jeff structures and analyzes both in-bound and out-bound transactions and investments and represents several Canadian pension funds in connection with their private equity, infrastructure and real estate investments in the U.S. Jeff also has extensive experience with real estate investment trusts, international financing transactions and structures, cross-border Canadian income funds, Canada-U.S. Income Tax Treaty issues, branch-versus-subsidiary considerations and international tax planning for high-net-worth individuals. His significant clients include Caisse de dépôt et placement du Québec, the Public Sector Pension Investment Board and various U.S. and non-U.S. investment banks and underwriters.
Representative Matters
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a U.S. real estate private equity fund in the sale of a non-U.S. portfolio to a Canadian public company;
- a U.S. governmental agency in the sale of a pool of commercial mortgages to a commercial mortgage trust;
- a U.S. underwriter in the sale of asset-backed securities issued by a commercial trust and secured by certain real estate receivables;
- a public Canadian income fund in its conversion into a public Canadian corporation;
- a French public corporation in connection with the structuring and implementation of a tax efficient refinancing of inter-company indebtedness of its U.S. group;
- a U.S. bank in connection with the restructuring of various structured investment vehicles;
- an asset management firm in connection with the formation and structuring of several TALF funds; and
- a Canadian pension fund in the purchase of various debt and equity interest in CDOs and similar investment structures.