Jeffrey R. Davine

Senior Counsel
Denver

Jeffrey R. Davine focuses on federal and local taxation, tax planning, and estate planning issues, including pass-through entities, business transactions, real estate taxation, certain employee benefits, tax controversies, and trusts, estates, and probate.

In addition, a continuing part of Jeffrey's practice involves formation of and representation of nonprofit entities. He has represented a symphony organization in connection with certain restructuring 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. Jeffrey 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.

Experience 

Representative Matters

  • Represented Visible Supply Chain Management in a $838 million acquisition by integrated container logistics company A.P Moller-Maersk, the world's largest container shipping and vessel operator
  • Representing and advising a broad range of buyers and sellers of businesses together with tax advice, planning, and structuring
  • Representation of auto finance companies, including the design of Delaware series LLC structures and preparation of contracts, operating agreements, and investment documents

Professional Highlights

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

Speaking Engagements

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

Publications

Jeffrey 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

Credentials 

Education

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)

Admissions

Colorado