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William M. Funk

Of Counsel, Tax Law

William M. Funk is a tax attorney with extensive experience in tax planning and dispute work. His practice focuses on businesses, funds, non-profit organizations. His clients include hedge funds, private equity funds, real estate partnerships, technology start-ups, manufacturers, not-for-profit organizations and high-net-worth individuals.

Mr. Funk’s experience includes structuring, documenting and negotiating a broad spectrum of domestic and cross-border transactions including acquisitions and dispositions, reorganizations, offerings, spin-offs, joint ventures and equity compensation. He has represented taxpayers before the Internal Revenue Service and the New York State Department of Taxation and Finance on a range of matters including audits, tax controversies and tax collections matters and successfully negotiated resolutions with respect to income tax, employment tax liabilities and penalties. Mr. Funk has obtained tax exemptions for charitable organizations, trade associations and other not-for-profit organizations and has advised on continued compliance, executive compensation, unrelated business income tax issues, cross-border grants and dissolutions.

In addition, Mr. Funk has written articles for Tax Notes, Business Entities, Taxes: The Tax Magazine, Journal of Taxation, Journal of Taxation of Investments and Opalesque. And he has taught continuing legal education programs on tax-exempt organizations and on tax ethics.


Tax Publications

  • U.S. Taxation of Sovereign Wealth Fund Investments in Funds (and Real Estate): Where We Stand Today, Journal of Taxation of Investments (Summer 2013)
  • Is the Trading Safe Harbor for Non-U.S. Tax Payers Compatible with the Section 475(f) Election?, Journal of Taxation (August 2011)
  • New U.S. Tax Guidance Provides Welcome Clarification for Check-a-Box Elections by Cayman Islands Entities, caymanhedgefunds.com (November 29, 2010)
  • Can Humanity Find the Meaning of Life in the Final Cash D Reorganization Regulations?, Taxes—The Tax Magazine (July 2010)
  • On and Over the Horizon: Emerging Issues in U.S. Taxation of Investments, Houston Business and Tax Law Journal (Autumn 2009)
  • The Sun Also Sets: Making the Most of TIPRA’s Changes to FIRPTA While They Last, Business Entities (September/October 2007)
  • The ABCs of UBTI: A Practical Guide to Avoiding Unrelated Business Taxable Income from Real Estate Investments, Practical Tax Lawyer (Fall 2004)
  • The Thirty-Years Tax War, Tax Notes International (October 1, 2001), also published in Tax Notes (October 8, 2001).

Bar & Court Admissions

• United States Tax Court

• New York State


Education

• L.L.M., 2004, New York University School of Law

• J.D., 1999, Vanderbilt University School of Law; Associate Articles Editor, Vanderbilt Law Review

• A.B., 1993, University of Chicago, Honors