Christina Novotny

Counsel

Cleveland
T +1.216.861.7295
F +1.216.696.0740

Overview

Christina Novotny is a tax attorney whose practice focuses on the federal tax treatment of real property transactions, specifically transactions involving partnerships, federal and state historic rehabilitation tax credits, federal and state new markets tax credits, qualified opportunity funds and Section 1031 tax-deferred exchanges. A former Big Five accounting firm CPA, she has the technical knowledge and experience to navigate tax issues and apply creative structuring solutions to solve problems her clients face.

Select Experience

Historic Tax Credits
  • Represented a developer with respect to an approximately $40 million rehabilitation and repurposing of a historic structure in Pittsburgh into a residential rental complex. Structuring needed to address both federal and Pennsylvania historic tax credits as well as a state grant.
Opportunity Funds
  • Has regularly assisted firm clients with the new Opportunity Zone program, including navigating the various rules and regulations released since the program’s inception. Recent representative experience includes advising on the structure and documentation for a $20 million private qualified opportunity fund offering targeting investment in both real estate and start-up opportunity zone projects in the southern United States.
New Markets Tax Credits
  • Represented a community development entity (CDE) with respect to its involvement in a $50 million conversion of a historic structure in northwest Ohio into a corporate headquarters.
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Experience

Historic Tax Credits
  • Represented a developer with respect to an approximately $40 million rehabilitation and repurposing of a historic structure in Pittsburgh into a residential rental complex. Structuring needed to address both federal and Pennsylvania historic tax credits as well as a state grant.
  • Served as tax counsel to a New York not-for-profit corporation in connection with federal and state historic tax credit financing for its approximately $14.5 million historic rehabilitation of a former church building into a community performance venue. Assistance included advice on combining other financing sources (e.g., loans, grants and capital campaign dollars) with tax credit financing.
  • Served as tax counsel to a private university located in the Midwest in connection with the approximately $42 million historic rehabilitation of its sports arena. The engagement involved the "lease pass-through" model and sophisticated structuring resulting from the participation of exempt organizations.
Opportunity Funds
  • Has regularly assisted firm clients with the new Opportunity Zone program, including navigating the various rules and regulations released since the program’s inception. Recent representative experience includes advising on the structure and documentation for a $20 million private qualified opportunity fund offering targeting investment in both real estate and start-up opportunity zone projects in the southern United States.
New Markets Tax Credits
  • Represented a community development entity (CDE) with respect to its involvement in a $50 million conversion of a historic structure in northwest Ohio into a corporate headquarters.
  • Assisted a Cleveland nonprofit performing arts center in the acquisition and rehabilitation of a historic office building. The approximately $41.5 million project was financed with the assistance of federal and state new markets tax credits, as well as federal and state historic rehabilitation tax credits.
Energy Tax Credits
  • Member of a team that served as tax counsel to an insurance company in connection with its investment in a solar energy facility, which is anticipated to generate more than $40 million in energy tax credits.
Section 1031 Transactions
  • Regularly assists firm clients with tax-deferred Section 1031 exchanges (including reverse and multiple property exchanges). Such assistance includes drafting and reviewing documents (including exchange agreements, qualified exchange trust agreements, qualified exchange accommodation agreements, identifications and notices) and advising on structures (including tenancy-in-common structures).
  • Recent representative experience includes serving as tax counsel for: (i) an approximately $45 million deferred like-kind exchange involving an Ohio shopping mall; (ii) an approximately $46 million reverse exchange involving a Texas office property; and (iii) a simultaneous like-kind exchange involving multiple tenant-in-common interests in various mixed-use real estate projects located in Denver, Colorado.
Tax Settlement
  • Assists taxpayers with settling outstanding tax debt with the IRS and the state of Ohio, specifically including filing and negotiating Offers in Compromise and Installment Agreements. Recent representative experience includes settling taxpayer's IRS debt for approximately 10 percent of the amount due and state of Ohio debt for approximately 40 percent of the amount due.

Recognitions and Memberships

Memberships

  • Tax Club of Cleveland
  • American Bar Association
  • Ohio State Bar Association
  • Cleveland Metropolitan Bar Association
  • Notre Dame Club of Cleveland
    • Lawyers’ Alumni Committee

Pro Bono

  • Represented a local woman whose wages were being garnished by the IRS. Obtained "Innocent Spouse Relief" on her behalf in an amount close to $12,000 (back taxes plus interest).
  • Legal Aid Brief Advice Clinic Organizer

Emerging Issues

Admissions

  • U.S. Tax Court, 2008
  • U.S. District Court, Northern District of Ohio, 2008
  • Ohio, 2007

Education

  • J.D., Notre Dame Law School, 2007, magna cum laude
  • B.B.A., Accounting, Ohio University, 1999, summa cum laude
  • B.A., Spanish, Ohio University, 1999, summa cum laude