Edward J. Hannon, Partner

Biography

Edward J. Hannon is the chair of the firm’s Business Law Practice Group in Chicago. He works with clients in adopting tax savings structures for acquisitions and dispositions of privately-held, family-owned businesses. Ed also advises clients on the use of tax-oriented structures in real estate transactions.

Representing real estate owners and investors throughout the U.S., Ed addresses tax, governance, and entity formation and dissolution issues. He also advises non-U.S. investors in structures designed to minimize U.S. tax costs related to U.S. real estate investment. Ed has significant experience advising real estate companies in structures that facilitate tax-free like-kind exchanges under Section 1031 of the Internal Revenue Code, including the Delaware statutory trust structure and the tenant in common structure. He has also represented developers in connection with the pursuit and completion of opportunity zone-related projects:

  • Representing a Chicago-based private equity firm in a transaction involving a roll-up of an automotive-based service sector. The transaction involved subsidiaries in the United States, Germany, and the United Kingdom.
  • Representing a strategic buyer in the acquisition of a competitor in the revenue cycle business.
  • Representing a closely-held strategic buyer in the acquisition of a supply chain merger in a partially tax-free equity rollover transaction involving sub-tier limited liability companies.
  • Representing a developer in a mixed-use development project in connection with a significant investment by a qualified opportunity income fund and advised on the adoption of terms intended to qualify for tax-favored treatment as a qualified opportunity income partnership.
  • Assisting a foreign real estate company in the acquisition of a U.S. hotel property located in the U.S. Coordinated cross-border tax planning strategies with the client’s international accounting firm and developed strategies to minimize U.S. tax consequences of U.S. withholding tax and tax reporting requirements.
  • Representing real estate owners in like-kind exchange on adoption of post-exchange refinancing structure. Directed issuance of tax opinion on the extraction of the refinancing proceeds in a tax free manner.
  • Represented a foreign real estate company in connection with the acquisition of a hotel property located in the U.S. This matter involved the coordination of various cross-border tax planning strategies with the client’s international accounting firm and the development of a strategy to minimize the U.S. tax consequences of U.S. withholding tax and tax reporting requirements.
  • Represented real estate owners involved in a like-kind exchange in connection with the adoption of a post-exchange refinancing structure. This matter involved the issuance of a tax opinion on the extraction of the refinancing proceeds in a tax free manner and the development of the structure for the initial acquisition of the property by the like-kind exchange buyer and the subsequent refinancing.
  • Represented Swedish-based technology company in the negotiation of various joint venture agreements in connection with the expansion of their business into the United States.
  • Represented owners of a closely held corporation in the manufacturing industry in a stock sale to a U.S. buyer. This matter involved the development of a structure for the tax-free rollover of management-held shares, and the review of the tax consequences of the receipt of deferred purchase price in the form of stock of a thinly traded entity.
  • Represented a German-based company in connection with the sale of one of its U.S. subsidiaries to a strategic buyer and competitor. This transaction involved the negotiation of various tax sharing provisions and the adoption of a structure to minimize U.S. tax withholding costs on the distribution of the sale proceeds.

Legal Services

Education and Honors

  • Northwestern University, Kellogg School of Management, Certificate, Quarles & Brady Leadership Program (2016)
  • Georgetown University Law Center (LL.M., with distinction)
    • Certified Public Accountant, Illinois.
  • Loyola University Chicago School of Law (J.D.)
  • St. Louis University (B.S.)

Bar Admissions

  • Illinois

Court Admissions

  • U.S. Tax Court

Professional and Civic Activities

  • Adjunct faculty at the DePaul University Graduate School of Business (1998 - present)
  • Illinois CPA Society, (Board of Directors, 2009 - 2017; Chairperson 2015-2016)
  • Illinois State Bar Association, Federal Tax Section (Past-Chair, 2002 - 2003)
  • Ireland Network of Chicago (Member)

Professional Recognition

  • Selected as an Illinois Leading Lawyer - Leading Lawyers Network, Real Estate: Finance; Tax: Business - 2017 (cited in multiple years)
  • Leading Lawyers - International Business and Trade Law, Real Estate Law and Finance and Tax Law - 2012 (cited in multiple years)
  • Irish Legal 100 - 2012 (cited in multiple years)
  • Illinois Super Lawyers - 2010 (cited in multiple years)
  • Recipient of the Distinguished Alumni Medal from St. Ignatius College Prep (2008)