Mark S. Lange

Partner

Atlanta
T +1.404.256.6686
F +1.404.459.5734

"Interviewees describe Mark Lange as 'very knowledgeable and hard-working.' He assists with transactional tax matters... [and] has experience in tax exemption matters."

— Chambers USA 2020

Overview

Mark Lange focuses his practice on transactional tax matters, counseling clients on domestic and international corporate mergers and acquisitions, partnerships, and joint ventures. Mark also has substantial experience in advising on a range of tax-exempt entity matters for clients, concentrated primarily in the healthcare industry.

He regularly represents clients before the Internal Revenue Service and state departments of revenue. 

Select Experience

  • Represented a private equity fund in the sale of five of its portfolio companies providing tax free rollover equity to a large group of senior management.
  • Represented tax exempt trade association in an internal reorganization with taxable subsidiaries.
  • Obtained the first IRS private letter ruling involving a tender-offer procedure related to the private business use of the proceeds from tax-exempt bonds.
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Experience

  • Represented a private equity fund in the sale of five of its portfolio companies providing tax free rollover equity to a large group of senior management.
  • Represented tax exempt trade association in an internal reorganization with taxable subsidiaries.
  • Obtained the first IRS private letter ruling involving a tender-offer procedure related to the private business use of the proceeds from tax-exempt bonds.
  • Represented a large healthcare private equity firm in the sale of one of its portfolio companies that was a provider of medical equipment solutions to the hospital market.
  • Represented a large joint venture in structuring its acquisition of a large senior living facility through a REIT structure.
  • Represented a well-known public charity in a multiyear IRS audit targeting these kinds of nonprofit organizations around the country in recent years. The IRS audit resulted in less than $1,000 of tax owed despite significant Section 4958 excess benefit transaction and unrelated business taxable income issues being raised.
  • Represented a major international travel company in a possible tax indemnity claim related to a prior stock acquisition in which two states claimed that the acquired travel company failed to pay sales tax on travel-related services provided over the internet.
  • Represented a private equity fund in structuring a partially tax-free reorganization of five portfolio companies into a new LLC holding company with new senior debt, mezzanine debt and preferred equity.

Recognitions and Memberships

Recognitions

  • Chambers USA: Tax (2006 to 2020)
    • Band 3 (2019 to 2020), Band 2 (2018), Band 1 (2016 to 2017)
  • The Legal 500 United States (2014 to 2015, 2018)
    • Mergers and Acquisitions, Domestic Tax: East Coast (2014 to 2015)
    • Recommended in Tax: U.S. Taxes - Non-Contentious (2018)
  • Georgia Trend “Legal Elite” (2011, 2016)
  • Martindale-Hubbell: AV Preeminent
  • The Best Lawyers in America® (2013 to Present)
    • Georgia: Tax Law
  • Georgia “Super Lawyer” (2015, 2016)

Memberships

  • The Best Lawyers in America©
    • Georgia: Tax Law (2013 to Present)
  • American Bar Association
    • Section of Taxation
    • Health Law Section
  • American Health Lawyers Association
  • State Bar of Georgia: Tax Section
  • The Florida Bar
    • Healthcare Section
    • Section of Taxation
  • Atlanta Bar Association

Industries

Admissions

  • Georgia
  • Florida

Education

  • J.D., Indiana University School of Law, cum laude
  • M.S., Tax, DePaul University, with highest distinction
  • B.S., Purdue University, with highest distinction