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Charles M. Adelman
Charles Adelman's practice is focused on the tax aspects of investment vehicles and financial instruments, including mortgage-backed and asset-backed securities.
He regularly addresses issues involving the classification and qualification of investment arrangements such as grantor trusts, real estate mortgage investment conduits, real estate investment trusts, regulated investment companies, and offshore vehicles. His practice also concentrates on the taxation of financial instruments, including the classification of various structured products as debt or equity instruments, the treatment of sales and financing transactions, and the time value of money rules.
Charlie has been involved in the securitization of residential, multifamily, commercial, co-op, home equity, home improvement, and timeshare mortgage loans, as well as auto loans, credit card and trade receivables, boat loans, insurance policy loans, leases and other financial assets. His practice includes advising real estate investment trusts. In the commercial mortgage securitization area, Charlie represented the Resolution Trust Corporation on the tax aspects of its "C" Series commercial mortgage securitization program and advises on the structuring and qualification of multifamily and commercial loan securitizations, including conduit, large loan, and stand-alone securitizations. He regularly advises issuers and underwriters, and assists trustees and servicers in the ongoing administration of transactions.
Charlie has co-authored a chapter on "Taxation" in the Mortgage and Asset Backed Securities Litigation Handbook (T. Franklin and T. Nealon, eds. 2009) and has written articles in his field, including "Tax Issues in Structuring Asset-Backed Securities," Bank Accounting and Finance (Spring 1990) and "Tax Considerations" in The Asset Securitization Handbook (P. Zweig ed. 1989). He has spoken on the tax issues of mortgage-backed securities and asset-backed securities at industry conferences.
Charlie is a member of the Tax Section (Committee on Financial Transactions) of the American Bar Association, the Tax Section (Committee on Securitization) of the New York State Bar Association, the Tax and Accounting Subcommittee of the Regulatory Committee of the Commercial Mortgage Securities Association, and the Tax Committee of the American Securitization Forum (Chair, July 2007 - June 2010).
A cum laude graduate of Cornell University, Charlie earned a J.D., with distinction, from Cornell Law School, where he was a Managing Editor of the Cornell Law Review and a member of the Order of the Coif. He received his LL.M. in Taxation from New York University School of Law.
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