Profil
James O. Lang focuses his tax and corporate project finance practice on tax incentive programs, Qualified Opportunity Zone and Qualified Opportunity Fund financing, tax credits, and related state and federal incentive programs. Jim is closing over $15 billion of Qualified Opportunity Funds and ancillary Qualified Opportunity Zone deployment of funds and has closed or is structuring several billion dollars in tax credit incentivized transactions. Jim and his team have accomplished more than 750 QOZ deployments and more than 300 captive QOF formations for high-net-worth individuals and family offices.
Jim represents funds, investors, lenders, community development entities, and for-profit and not-for-profit project sponsors in complex transactions where capital stacks require enhancement through incentive financing, including Qualified Opportunity Zone incentives, state and federal new markets tax credits, affordable housing and low-income housing tax credits, historic rehabilitation tax credits, and renewable energy tax credits. He works with funds, investors, lenders, project sponsors, and qualifying businesses to structure these tax incentive programs along with ancillary governmental and non-governmental financing programs, including inbound immigration and Visa investment programs, grants, and taxable and tax-exempt bonds. Jim works with clients on developing creative structures designed to increase benefits and ameliorate risks.
Concentrations
- Qualified Opportunity Zones
- Qualified Opportunity Funds
- Tax credit incentive programs
- New Markets Tax Credit Program
- Tax exempt organization finance
- Real estate development
- Operating business expansion
- Affordable housing
- Project finance
Kluczowe Praktyki
Doświadczenie
- Qualified Opportunity Zone Funds
- 4 Multi-asset Qualified Opportunity Zone Funds of $500,000,000 - $1,000,000,000
- 12 Multi-asset Qualified Opportunity Zone Funds of $100,000,000 to $500,000,000
- 6 Single Qualified Opportunity Zone Funds of $20,000,000 to $100,000,00
- At least 12 Captive O-Funds
- Representation for the largest Qualified Opportunity Zone Fund mergers in the program’s nascent history. The mergers consolidated more than 20 funds representing the largest consolidated Qualified Opportunity Fund in the market. The consolidated Funds hold more than $939 million of invested capital.
- Closed on the formation of a new qualified opportunity fund for a Wisconsin-based family office investor.
- Representation of a real estate developer in connection with the formation of a qualified opportunity fund and qualified opportunity zone business to redevelop a full city block in Brooklyn, including commercial and residential spaces.
- Representation of a private investment fund in its $2.2 million investment into a qualified opportunity zone business joint venture for a Miami real estate development with a project budget of $100 million.
- Representation of a real estate investment group in structuring a $19.6 million qualified opportunity zone business joint venture for a Huntsville, Alabama development project.
- Representation of a real estate investment fund for the formation and support of a 355-unit multifamily qualified opportunity zone project adjacent to a major sports facility in Goodyear, Arizona.
- Representation of a qualified opportunity fund in its investments totaling approximately $79 million across joint ventures for multifamily real estate developments in Tucson, Arizona and New Brunswick, New Jersey.
- Representation of a qualified opportunity fund in its $28 million investment in a multifamily real estate development joint venture in New Brunswick, New Jersey with a total project budget of $180 million.
- Representation of a qualified opportunity fund in its $20 million investment in a multifamily real estate development joint venture in New Brunswick, New Jersey with a total project budget of $74 million.
- Representation of a qualified opportunity fund in the closing of a qualified opportunity zone business joint venture for an $85 million real estate development in the Southeast US.
- Representation of a real estate developer in the liquidation and reinvestment of capital among multiple qualified opportunity zone business projects.
- Representation of a multifamily developer in closing a $20 million investment for a Miami, Florida apartment community project.
- Representation of a multifamily real estate developer in the acquisition and development of a $112 million apartment complex in the Arts District of Las Vegas, including negotiation of a joint venture and $58.3 million construction financing.
- Representation of a qualified opportunity fund and qualified opportunity zone business for a $30 million investment in a multifamily development joint venture in San Diego, California with a total project budget of $87 million.
- Formation and offering of a $6.4 million qualified opportunity fund to invest in a residential real estate development in Austin, Texas.
- Representation of an opportunity zone investor and affiliate in the redemption of minority interests in a qualified opportunity fund and qualified opportunity zone business for a $4.5 million self-storage facility in North Carolina.
- Representation of a sports-focused opportunity zone fund in the documentation of Series A and Series B offerings totaling up to $26 million to fund the construction of a soccer stadium and development of a professional soccer team in Pawtucket, Rhode Island.
- Representation of a sports facility operator in a joint venture to develop USL soccer stadiums and ancillary facilities nationwide using an opportunity zone fund.
- Representation of a firm focused on workforce housing in the Southeastern US for operating documents of a $60 million qualified opportunity fund offering.
- Representation of a fully integrated real estate development firm in a $17.85 million apartment community development in Augusta, Georgia as a qualified opportunity zone business.
- Representation of a fully integrated real estate development firm in a $58.1 million 300-unit multifamily rental community project in Panama City, Florida as a qualified opportunity zone business.
- Representation of a real estate development firm in the formation of a new qualified opportunity zone business for a $45 million residential real estate project in Augusta, Georgia.
- Representation of a real estate development firm in the formation of a new qualified opportunity zone business for a residential real estate project in Hardeeville, South Carolina.
- Representation for a $90 million qualified opportunity fund in the formation and deployment of capital into six captive qualified opportunity zone businesses in South Florida.
- Representation of a logistics company in the acquisition of Chicago area real estate located in a qualified opportunity zone for $33.4 million using a newly formed fund and business structure.
- Representation of two qualified opportunity funds in their aggregate $1.25 million initial investment in a Tallahassee real estate joint venture with a $186 million project budget.
- Representation of a real estate-focused qualified opportunity fund in its formation and $25 million securities offering.
- Representation of a qualified opportunity fund’s $7.6 million co-investment in a student housing joint venture in Gainesville, Florida.
- Representation of a qualified opportunity fund in its $7 million investment in a multifamily development joint venture in Los Angeles, California with a $33 million project budget.
- Representation of a real estate investment fund in its $15 million opportunity zone investment in a mixed-use real estate project in Salt Lake City, Utah.
- Representation of a New York-based real estate fund manager in the closing of a managed $30 million single asset investment fund structured as a qualified opportunity fund.
- Representation of a New York-based real estate fund manager in the closing of a real estate joint venture structured as a qualified opportunity zone business in Charlotte, North Carolina with a $103 million development budget.
- Representation of a New York-based real estate fund manager in the closing of a managed $11.5 million investment fund structured as a qualified opportunity fund.
- Representation of an investment group in the acquisition of a student housing complex under development in a Tallahassee qualified opportunity zone for $135.5 million.
- Representation of a vertically integrated multifamily real estate developer for the development of an $89.5 million mixed-use project in Tampa Heights, including residential, retail, and parking spaces.
- Representation of a real estate investment group in its $2.76 million investment in a Miami Design District development, structured as a qualified opportunity zone business.
- Representation of the sponsor of a qualified opportunity zone business joint venture in Los Angeles for its formation and a $7 million securities offering.
- Representation of a multifamily real estate investment firm for a new $8 million preferred equity offering in a qualified opportunity fund for a New Jersey project.
- Representation of the entity responsible for the formation and development of Tampa’s new USL Super League women’s soccer team, structured as a qualified opportunity zone business.
- Representation for a $10 million New Markets Tax Credit transaction for the acquisition, development, construction, and outfitting of a 34,000 square foot job training center and adjacent donated goods retail store in Atlanta, Georgia.
- Representation for $73 million New Markets Tax Credit financing structure for the National Urban League’s new empowerment center (offices, museum, and 177 affordable housing units) comprised of $12.9 million New Markets Tax Credits transaction, $22.5 million of municipal bond financing, $34.7 million of Low-Income Housing Tax Credits (LIHTC), and $3 million from the Federal Housing Trust Fund to spur investment in a distressed urban area in New York City.
- Representation of a Purpose-Built Community organization, in its multiple-project New Markets Tax Credits strategy for early child learning and community healthcare outreach.
- Representation of a financial institution in a New Markets Tax Credits transaction with a national nonprofit for children in a New Markets Tax Credits transaction for a new facility in Houston in a $6.5 million transaction.
- Representation of a national nonprofit in a $5 million New Markets Tax Credits transaction supporting the capital campaign to build an 18,234 sf state-of-the-art educational facility that expands financial education to students.
- Representation of a not-for-profit organization that is a sports based youth development organization focusing on promoting sports intentionally infused with life skills and academics and primarily targeting minority children in the greater Tampa Bay area, the sponsor in a $20 million New Market Tax Credits transaction, which will support the development of a new charity headquarters for the organization and academic and sports programming facility.
- Representation of a not-for-profit organization that focuses on providing a healthy thriving, sustainable, food system in the greater Orlando area, the Sponsor in a $16.75 million New Market Tax Credit transaction, which will support the development of a food education and discovery center.
- Representation of a youth development and community organization, in a $9.8 million New Markets Tax Credits unwind transaction.
- Representation of a chain of convenience stores and gas stations, in a $10.8 million New Markets Tax Credits transaction for the development and operation of a new retail gas station and convenience store.
- Representation of a nonprofit healthcare provider in the unwind of a $5.94 million New Markets Tax Credit transaction.
- Representation of a Nebraska-based manufacturing company in the unwind of a $16.5 million New Markets Tax Credit investment structure involving both federal and state credits.
- Representation of a Florida municipality in the unwind of a $16 million New Markets Tax Credit investment structure for public infrastructure development.
- Representation of a nonprofit community development organization in its affordable housing project involving a $6 million New Markets Tax Credits allocation.
- Representation of a marine services corporation in the unwind of an $8.1 million New Markets Tax Credit transaction.
- Representation of a global data center infrastructure provider in the refinancing of a $25 million loan as part of a New Markets Tax Credits transaction structure.
- Representation of a leading snack food manufacturer in a $24 million New Markets Tax Credit transaction.
- Representation of a community hospital in Chipley, Florida in closing a $9 million New Markets Tax Credit transaction to fund an ambulatory surgical center development.
- Representation of an asset management company in the acquisition of three source loans totaling $18 million, integrated into New Markets Tax Credits structures.
- Representation of a Puerto Rico hospital in the unwind of a $16 million New Markets Tax Credit investment structure.
- Representation of a convenience store chain in the unwind of a $38 million New Markets Tax Credit investment structure.
- Represented a direct and leveraged lender in the unwind of a $19 million New Markets Tax Credit transaction.
- New Markets Tax Credits transaction for a non-profit’s a new $6.5 million facility.
- New Markets Tax Credits transaction to support the capital campaign to build a non-profit’s new educational facility.
- Representation of a municipality for in a $16 million New Markets Tax Credits transaction for the development of a multi-modal facility supporting revitalization.
- Representation of marine service contractor in a $8.25 million New Markets Tax Credits transaction for business and workforce expansion.
- Representation of a food processor in a $13.3 million New Markets Tax Credits transaction for a Clean Energy Plant investment. A second phase $13.5 million New Markets Tax Credits transaction expanded the clean energy plant.
- Representation of food processor in a $4.85 million New Markets Tax Credits transaction for a Clean Energy Plant improvement
- Representation of a real estate developer for a $20 million New Markets Tax Credits transaction for a redevelopment project of a mixed-use facility which includes 16 walk-up vendors, two restaurants, a rooftop bar, event space, and theater in an economically challenged area
- Representation of real estate developer in connection with a $19 million New Markets Tax Credits transaction to develop and construct an adaptive reuse of a historic building in a low-income community.
- Representation of a laboratory in a $34 million New Markets Tax Credits transaction for the development and equipping of its new pharmaceutical manufacturing plant in Puerto Rico.
- Representation of an agricultural and heavy-duty equipment manufacturer in Nebraska in a $10.7M New Markets Tax Credits transaction.
- Representation of a $15.3 million New Markets Tax Credits deal to construct, rehabilitate, and install various projects in a hospital.
- Representation for what is planned to be the development of the world’s largest carbon capture and storage project. This approximately $4 billion project will link dozens of carbon dioxide emission sources, primarily biorefineries from across the Midwestern United States to permanent geologic storage sites. This project will include carbon capture operations, CO2 pipelines extending over 2,000 miles, the largest pipeline project in the U.S. in over 50 years, and permanent geological sequestration.
- Representation of a financial institution in a solar investment tax credit transaction
- Tax opinion counsel for affordable housing project development
- Tax credit investment counsel for an insurance company
- Representation of an independent energy producer for cross-border tax issues and qualification for energy tax credits in support of the design, development, and operation of a $95 million utilities services facility serving a $500+ million recycling and purification plant in Georgia.
- Representation of a New Jersey-based real estate developer in its $94.5 million purchase and historic rehabilitation of a luxury hotel in Manhattan, generating federal historic tax credits.
- Representation of a real estate developer in closing a federal historic tax credit transaction involving $5.9 million historic tax credits for the rehabilitation of a historic hotel in Raleigh, North Carolina.
- Representation of a tax credit fund’s $19.1 million equity investment in a $22 million low-income housing tax credit transaction for the development and operation of four residential apartment complexes in Fort Myers, Florida.
- Representation of a Texas design media brand with the structuring and financing of a hotel and resort development project with an HTC component in an Opportunity Zone in Waco, TX with an estimated budget of at least $35M based on loan commitments.
- Representation of a bank in its acquisition of $20M of production tax credits.
- Representation of a developer on a LIHTC transaction in Miami, FL involving master covenants and bond financing.
- Representation of a banking institution’s $20 million investment in a syndicated $200 million Low-Income Housing Tax Credit Fund.
- Representation of a banking institution’s $25 million investment in a syndicated $235 million Low-Income Housing Tax Credit Fund.
- Representation of a banking institution’s $10 million investment in a syndicated $180 million Low-Income Housing Tax Credit Fund.
Wyróżnienia i aktywność zawodowa
- Listed, Chambers USA Guide, "Up and Coming," Tax, 2024-2025
- Listed, The Best Lawyers in America, Tax Law, 2023-2026
- Team Member, a Law360 "Real Estate Practice Group of the Year," 2023
- Selected, Opportunity Zone Magazine, “Top 25 OZ Attorneys,” 2021
- Listed, The Legal 500 United States, Tax - US Taxes: Non-Contentious, 2021 and 2023
- Listed, Tampa Bay Business Journal, "40 Under 40," 2020
- Selected, Opportunity Zone Magazine, "Top 25 OZ Influencer," Ranked #11 – second attorney in ranking, 2020
- Selected, Daily Business Review, "Florida Trailblazers," 2019
- Team Member, a Law360 "Florida Powerhouse," 2018
- Selected, ABA “On the Rise – Top 40 Young Lawyers,” 2018
- NAIOP Tampa Bay Chapter, "Best Urban/Infill Project: Armature Works," 2018
- Chair, Tampa Bay Economic Development Council, International Committee, 2017-2018
- Member, Board of Directors, Junior Achievement of Tampa Bay
- Member, American Bar Association
- Lead Advisor, Florida New Markets Tax Credits Alliance Legislative Action Committee
- Chairman, Legislative Drafting Committee for a Revised Florida New Markets Development Program Act, Florida New Markets Tax Credits Alliance
- Member, Hillsborough County Bar Association
- Advisor, Sunshine State Low-Income Community Advocacy Coalition, Inc.
- Advisor, The Black Farmers Rural Funding Initiative, Inc.
- Advisor, The Young Men’s Christian Association of Greater St. Petersburg, Florida
- Member, University Club of Tampa
- Member, Florida Blue Key
- Member, Kiwanis Club, Tampa
- Alumnus, Florida Alpha Omega Chapter of Alpha Tau Omega Fraternity, University of Florida
Wykształcenie i uprawnienia do wykonywania zawodu
Wykształcenie
- J.D., Florida State University College of Law
- B.A., University of Florida
- LL.M., University of Florida
Uprawnienia
- Florida
- New York
Aktualności, publikacje i wystąpienia
James is a contributor to the GT Israel Law Blog 