Overview
Heath Martin is a partner in Chapman's Tax Department. His practice covers a wide variety of U.S. federal and international tax matters. Heath has extensive experience advising on the formation and operation of investment funds, public and private offerings of debt and equity, mergers and acquisitions, stock and asset purchases, reorganizations and restructurings, equity incentive plans and deferred compensation plans, FACTA compliance, green energy tax credits and tax equity investments, and tax-exempt organizations.
Prior to joining Chapman, Heath practiced in the New York office of a large Canadian law firm and has extensive experience advising non-U.S. institutional and private investors on the tax aspects of deploying capital in the United States.
Admitted
Massachusetts
New York
Education
London Business School, MSc, 2011
Stanford Law School, JD, 2003
Brown University, PhD, 2000
Boston University, BA, 1993
Notable Engagements
Fintech Company AcquisitionChapman represented YieldX, a portfolio management technology company, in its acquisition by FNZ, a global wealth management platform. The acquisition of YieldX is part of FNZ’s growth plan to expand its wealth management solutions in the US and around the globe. The sale of YieldX to FNZ was structured as a tax efficient forward triangular merger and followed a regulatory strategy and several successful venture round financings in which Chapman worked closely with the YieldX founders.
All Year Holdings Bond RestructuringChapman served as US counsel to the indenture trustee in the successful consummation of the Chapter 11 Plan of Reorganization for All Year Holdings Ltd., a British Virgin Islands company whose US subsidiaries were engaged in the acquisition and development of real estate projects located in New York.
Acquisition of Two Gaming Companies in New HampshireChapman served as lead counsel to Clairvest Group Inc. and its affiliates in the acquisition of NHCG, LLC and The River Property & Hospitality Group, LLC, which operate the Lucky Moose Casino and Tavern and The River Casino & Sports Bar in Nashua, New Hampshire.
Acquisition and Financing of Wyoming Downs and Gaming OperationsChapman served as lead acquisition and financing counsel in a joint acquisition of Wyoming Downs, a live horse racing and off-track gaming facility which includes historical horse racing and simulcast throughout the state of Wyoming.
Insights
Publications
- Co-Author, "The Evolution of U.S. Tax Rates and Related Matters Since 2017 — In a Canadian Context," 50 Tax Mgmt. Int'l J. 11 (Nov. 5, 2021).
- Co-Author, "Getting Burnt by a Cross-Border Freeze: Traps for the Unwary Under Code Sec. 2701," CCH Int'l Tax J. (July–August 2021).
- Co-Author, "Guidance on Qualified Shareholders of REITs Still Lacking," 67:4 Canadian Tax J. 1309 (2019).
- Co-Author, "International Insight: Not Whether but When and How: US Response to Unilateral Digital Taxation," Tax Mgmt. Int'l Forum (Oct. 30, 2019).
- Co-Author, "Consolidated Reporting in the United States," Tax Mgmt. Int'l Forum (2019).
- Co-Author, "United States: CFC Rules," 39 Tax Mgmt. Int'l Forum 82 (Issue No. 4, Dec. 2018).
- Co-Author, "U.S. Supreme Court Decision Permits States to Tax Online Retailers Without Any In-State Physical Presence," 47 Tax Mgmt. Int'l J. 536 (Aug. 10, 2018).
- Co-Author, "United States: Sharing Economy," 39 Tax Mgmt. Int'l Forum 76 (Issue No. 3, Sep. 2018).
- Co-Author, "United States: Source-Residence Country Coordination," 39 Tax Mgmt. Int'l Forum 117 (Issue No. 2, June 2018).
- Co-Author, "United States — Acquisition Financing," 39 Tax Mgmt. Int'l Forum (Issue No. 1, Mar. 2018).
- Co-Author, "Tax Traps for the Unwary: United States," 38 Tax Mgmt. Int'l Forum 97 (Issue No. 4, Dec. 2017).
- Co-Author, "Lessons from Canada and the WTO: The United States Should Embrace A VAT," 46 Tax Mgmt. Int'l J. 206 (April 14, 2017).
- Co-Author, "IRS Should Allow QCIV Self-Designation Under FIRPTA," 45 Tax Mgmt. Int'l J. 734 (Dec. 9, 2016).
- Co-Author, "Will Canadian Pension Plans Feast on U.S. Infrastructure (Without FIRPTA)?," 45 Tax Mgmt. Int'l J. 217 (Issue No. 04, April 2016).
- Co-Author, "U.S. Tax Concerns Facing Foreign Lenders," J. of Tax'n and Reg. of Fin. Institutions (January / February 2016).
- Co-Author, "Fund Management Fee Waivers Under Attack," CCH Int'l Tax J. (Nov./Dec. 2015).
- Co-Author, "IRS Limits Deferral Opportunities Through Controlled Partnerships," 63:4 Canadian Tax J. 1123-32 (2015).
- Co-Author, "U.S. Model Treaty's Proposed Revisions Contrasted to Current Canadian Convention," 44 Tax Mgmt. Int'l J. 494 (Issue No. 8, Aug. 14, 2015).
Presentations
- "New IRS Partnership Audit Rules for Tax Counsel: Preparing for Massive Changes Ahead," Strafford, January 2016, March 2016, February 2017, May 2018, August 2018, and July 2020.