Samuel P. Grilli

Partner

Baker & McKenzie LLP

Chicago

T + 1 312 861 2522
F + 1 312 698 2764

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Biography

Samuel Grilli is a partner in the Tax Practice Group of the Chicago office. He provides tax structuring advice to US and multinational clients. He also represents clients in domestic tax disputes. Sam is a regular contributor to the Journal of Taxation, and a frequent speaker at tax conferences, including at meetings of the Tax Section of the American Bar Association. In addition, Sam has served as chair of the Firm’s training concerning partnership taxation and actively assists pro-bono clients.

Practice Focus

Sam focuses his practice on federal income tax planning related to domestic and cross-border transactions. Sam advises clients on structuring partnerships and joint ventures, mergers and acquisitions, reorganizations, capital markets transactions, private letter rulings, real estate transactions, fund and real estate investment trust (REIT) structures and cross-border business or investment in the US.

Sam is experienced in tax matters related to professional sports teams, complex partnership transactions, REITs, sovereign wealth and pension funds, structured finance transactions, membership deposits, like-kind exchanges, and multinational clients investing or doing business in the US, especially with regard to inbound investments in US real estate involving the Foreign Investment in Real Property Tax Act (FIRPTA), treaty and other related issues. In addition, Sam is well experienced in advising, negotiating and drafting partnership and joint venture agreements, purchase-sale agreements and other related transactional agreements. Sam has served as chair of, and spoken at, the Firm’s training concerning partnership taxation held in coordination with the Chicago Chapter of the Tax Executives Institute (TEI).

Professional Associations and Memberships

American Bar Association - Member, Section of Taxation
National Association of Real Estate Investment Trusts (NAREIT) - Member

Admissions

Illinois~United States (2011)

Education

University of Chicago Law School (2011)
Cornell University (2004)

Languages

English

Co-author, "Private Funds and YA Global v. Commissioner: Time for a Health Check," Journal of Taxation, April 2024

Co-author, "Whether Moore or Less? Listen to the Oral Argument!" Journal of Taxation, February/March 2024

Co-author, "District Court Applies Section 7701(o) in Liberty Global, But Did It Misstate the Law?" Journal of Taxation, February/March 2024

Co-author, "Ruminations on Identification," Journal of Taxation, February/March 2024

Co-author, "The Taxpayer and Amicus Appellate Briefs in Tribune Media Throw Tough Pitches at the IRS," Journal of Taxation, November 2023

Co-author, "Taxation of Player Contract Trades-The IRS Reaches the Correct Result," Journal of Taxation, August 2019

Author, "Do Taxpayers Still Need to Sell Domestically Controlled REIT Shares to Avoid FIRPTA?" Journal of Taxation, May 2019

Co-author, "The 'State of the Art' in Like-Kind Exchanges-2019," Journal of Taxation, February 2019

Co-author, "New Regulations on Partnership Debt and Disguised Sales: Is the Road to Hell Paved with Good Intentions? (Part 2)," Journal of Taxation, March 2017

Co-author, "New Regulations on Partnership Debt and Disguised Sales: Is the Road to Hell Paved with Good Intentions? (Part 1)," Journal of Taxation, February 2017

Baker & McKenzie LLP is a Limited Liability Partnership organized under the laws of the State of Illinois (USA) and is a member of Baker & McKenzie International, a Verein organized under the laws of Switzerland.