Chicago Office
Tel: (312) 715-5094
Fax: (312) 632-1945

Edward J. Hannon

Partner

Ed Hannon is a member of the firm’s Business Law Practice Group and works with clients in adopting tax savings structures for acquisitions of privately-held, family-owned businesses. Ed also advises clients on the use of tax-oriented structures in real estate transactions.

Representing real estate owners and investors throughout the U.S., Ed addresses tax, governance, and entity formation and dissolution issues. He also advises non-U.S. investors in structures designed to minimize U.S. tax costs related to U.S. real estate investment. Ed has significant experience advising real estate companies in structures that facilitate tax-free like-kind exchanges under Section 1031 of the Internal Revenue Code, including the Delaware statutory trust structure and the tenant in common structure.

Ed is regularly involved in drafting and negotiating tax provisions included in stock purchase agreements, merger agreements, and tax sharing agreements used in acquisitions of U.S.-based businesses.

With respect to non-real estate transactions, Ed has represented strategic buyers and private equity firms in the acquisition and disposition of U.S. businesses ranging in value from $30 million to $500 million.

Ed's experience includes:

  • Representing a Chicago-based private equity firm in a transaction involving a roll-up of an automotive-based service sector. The transaction involved subsidiaries in the United States, Germany, and the United Kingdom.
  • Representing a strategic buyer in the acquisition of a $380 million competitor in the revenue cycle business.
  • Representing a closely-held strategic buyer in the acquisition of a supply chain merger in a partially tax-free equity rollover transaction involving sub-tier limited liability companies with a total transaction value of $120 million.
  • Representing the owners of six shopping malls in the contribution of the properties to a publicly registered non-traded REIT as seed properties. Adopted UPREIT structure to facilitate tax-free contribution of the properties to the REIT, modify existing loan agreements in connection with the transfer of the properties, and create a taxable REIT subsidiary.
  • Assisting a foreign real estate company in the acquisition of a U.S. hotel property located in the U.S. for $18 million. Coordinated cross-border tax planning strategies with the client’s international accounting firm and developed strategies to minimize U.S. tax consequences of U.S. withholding tax and tax reporting requirements.
  • Representing real estate owners in like-kind exchange on adoption of post-exchange refinancing structure involving $6.3 million in loan proceeds. Directed issuance of tax opinion on the extraction of the refinancing proceeds in a tax free manner.
  • Representing a real estate developer in joint venture agreement with nationally based student housing company on student housing and hotel project. Oversaw tax and structural planning arrangements in connection with receipt of TIF funding from a municipality in downstate Illinois.

Legal Services

  • Business Law
  • Corporate Venturing
  • Private Equity/Venture Capital
  • Privately Held Businesses
  • Tax
  • Mergers & Acquisitions
  • Real Estate
  • International Services

Education and Honors

  • Northwestern University, Kellogg School of Management, Certificate, Quarles & Brady Leadership Program (2016)
  • Georgetown University Law Center (LL.M., with distinction)
  • Certified Public Accountant, Illinois.
  • Loyola University Chicago School of Law (J.D.)
  • St. Louis University (B.S.)

Bar Admissions

  • Illinois

Court Admissions

  • U.S. Tax Court

Professional and Civic Activities

  • Adjunct faculty at the DePaul University Graduate School of Business (1998 - present)
  • Illinois CPA Society, (Board of Directors, 2009 - present; Chairperson 2015-2016)
  • Illinois State Bar Association, Federal Tax Section (Past-Chair, 2002 - 2003)
  • Ireland Network of Chicago (Member)

Professional Recognition

  • Selected as an Illinois Leading Lawyer - Leading Lawyers Network, 2017–present (Real Estate: Finance; Tax: Business)
  • Leading Lawyers - International Business and Trade Law, Real Estate Law and Finance and Tax Law - 2012 (cited in multiple years)
  • Irish Legal 100 - 2012 (cited in multiple years)
  • Illinois Super Lawyers - 2010-2017
  • Recipient of the Distinguished Alumni Medal from St. Ignatius College Prep (2008)

Publications

11/27/18
"No Deal Brexit: What U.S. Lawyers Need to Know"
The Lexis Practice Advisor Journal

11/02/18
Recent Guidance on Opportunity Zones Answers Some But Not All of the Issues
Real Estate Alert

09/13/18
Qualified Opportunity Zones: Formation and Investment Opportunities
Tax Law Alert

06/08/18
“2019 Brexit Implications for US Companies with UK Subsidiaries: What You Need to Know Now”
Quarles & Brady Seminar

02/01/18
"Tax Opportunities and Tax Traps for Real Estate Transactions"
Real Estate Finance Journal

02/01/18
Tax Opportunities and Tax Traps for Real Estate Transactions
Tax Law Alert

01/29/18
Update - The Effect of the Partnership Audit Rules on Tax-Exempt Investors
Investor Services Update

01/10/18
Do You Receive Incentives from State and Local Governments? Your Tax Liability Is Likely to Increase
Tax Law Alert

12/26/17
Tax Cuts and Jobs Act
Tax Law Alert

12/15/17
The Effect of the Partnership Audit Rules on Tax-Exempt Investors
Investor Services Update

07/10/17
Illinois Has a Budget – and Taxes Are Going Up
Tax Law Alert

04/28/17
The President's Tax Plan
Tax Law Alert

01/26/17
Like-Kind Exchange Structures for Property Held in a Multi-Member LLC - Tax Issues to Be Addressed in Every "Drop & Swap" Transaction
Tax Law Alert

03/10/16
"Using Delaware Statutory Trusts in Real Estate Investments: Opportunities and Legal Risks"
Strafford Live CLE/CPE Webinar

02/04/16
​New Partnership Rules Require Attention of Investors
Investor Services Update

08/27/15
"Keynote Address"
Illinois CPA Society Annual Conference

03/05/15
"Using Delaware Statutory Trusts in Real Estate Investments: Opportunities and Legal Risks"
Strafford Live CLE/CPE Webinar

12/02/14
"The Proliferation of Real Estate Investment Trusts and How to Deal With Them"
REJournals.com

11/01/14
Edward J. Hannon was a participant in a panel discussion on using net lease property in tax-free exchange
American Institute of Certified Public Accountants Real Estate Conference in Dallas, Texas

10/01/14
"Tax Planning for Property 'Sale' to an UPREIT"
Plante Moran Webinar

06/04/13
“Taxation on Real Estate Conference”
Illinois CPA Foundation

12/18/12
“Alternative Strategies for Note Purchasers”
NICAR Holiday Luncheon

10/24/12
“Note Auctions: What that means for a borrower?”
Webinar with 1st Service Solutions

10/23/12
“Tax Issues in Real Estate Loan Workouts, Foreclosures and Short Sales”

10/10/12
“Alternative Strategies for Note Purchasers: How Proper Utilization Can Improve the Bottom Line”
Webinar with Circle Realty Advisors, LLC

07/25/12
“Finding Leverage to Overcome Real Estate Frustration: Borrower Recapitalization”
Illinois CPA Society

06/01/12
“Answering the Unanswerable - How are the Experts Addressing Complex Tax Issues of Distressed Properties”
Illinois CPA Society, Taxation and Real Estate Conference

11/09/11
“Tax Issues in Real Estate Loan and Lease Workouts, Foreclosures and Short Sales”
Stafford

05/01/10
“Tax Planning for Distressed Real Estate”
Illinois CPA Society, Real Estate Taxation Conference

08/01/09
“Current Issues with Alternative Financing Vehicles”
American Bar Association, Annual Meeting

05/01/09
“Private Equity and Vulture Funds – Tax and Structural Issues”
Illinois CPA Society, Real Estate Taxation Conference

05/01/09
“TIC Workouts”
American Bar Association, Tax Section Annual Meeting