Jeffrey R. Davine

Jeffrey R. Davine is a partner in the Real Estate Department and a member of the Tax, Real Estate Tax, Commercial Real Estate Recovery, International, and Exempt Organizations Groups. He focuses his practice on federal and local taxation, tax planning, and estate planning issues, including pass-through entities, business transactions, real estate taxation, employee benefits, tax controversies, and trusts, estates, and probate.

A significant part of Mr. Davine's practice involves foreign tax matters. His international tax work includes: 

• Acquisition by foreign persons from various countries of U.S. real estate interests, passive investments, and operating businesses
• Participation by U.S. persons in joint ventures, limited liability companies, and corporations operating businesses in foreign countries including India, China, South America, the European Union, and Russia
• Investment by U.S. persons in foreign resort developments and transactions by which U.S. consumer promissory notes owed to foreign sellers of real estate interests may be collected (usually in a trust) and pledged to secure a loan to the foreign sellers in a manner that avoids U.S. withholding tax on payments of interest to the foreign sellers

A substantial part of Mr. Davine's practice involves formation of and representation of nonprofit entities. He represents a regional dairy tax-exempt educational organization and its affiliated nonprofit marketing arm and has formed a number of nonprofits, including those related to prevention of cruelty to animals, fostering amateur athletic competition, medical research, donation of property "in kind," and general charitable purposes. Work includes dealing with private foundation questions such as investment limitations, self dealing, mandatory payout requirements, excess business holdings, restricted investments, and excise tax on investment income. Mr. Davine has prepared applications for tax-exempt status under IRC Section 501(c)(3) and other sections, including title holding entities, social clubs, and business leagues.

Professional Activities

American Bar Association, Sales, Exchanges and Basis Committee; Foreign Activities of U.S. Taxpayers Committee; and U.S. Activities of Foreigners and Tax Treaties Committee

Colorado Bar Association

University of Denver Sturm College of Law, past adjunct professor, corporate taxation

Publications

Mr. Davine has published articles and spoken on partnership allocations and transactions, limitations on the use of corporate net operating loss carryovers, time value of money rules, the treatment of partnership interests issued as compensation, tax-deferred exchanges of tenancy-in-common interests, and nonqualified compensation plans.

Co-author, "Disregarded Entities Are Now Responsible for Their Own Employment Taxes," Practical U.S./Domestic Tax Strategies, WorldTrade Executive, Inc., July 2009

Speaking Engagements

"Troubled Debt and Workouts," Ballard Breakfast Briefing, June 4, 2009

University of Colorado Law School (J.D. 1977)

New York University School of Law (LL.M., taxation, 1978)

University of Colorado (B.A. 1973, summa cum laude; M.A. 1992)

Colorado