Melanie Gnazzo

Melanie Gnazzo is a partner in the Asset Securitization, Lease Finance and Tax practice groups at Chapman and Cutler LLP. She has considerable experience providing both tax and commercial law advice in a wide range of financial transactions and regularly represents finance companies and funding sources engaged in securitization, leasing and other structured finance transactions. She also provides advice with respect to tax advantaged investments, including those used to fund alternative energy assets. Ms. Gnazzo is a regular speaker at industry forums on tax, leasing and securitization matters.Select representative transactions include:Representation of various parties in connection with structuring financing for energy assets funded with proceeds of prepaid power purchases by municipal utilities and related joint power authoritiesRepresentation of institutional investors in tax advantaged solar energy transactions, including sale-leaseback, partnership-flip and loan transactionsRepresentation of arranger and tax equity investors in sale leaseback transactions involving ethanol production facilitiesRepresentation of several leasing companies in connection with portfolio acquisitions and dispositions, re-financings and restructurings in 2009 and 2010Representation of lender finance division of national bank in connection with various warehousing and asset based loans to finance companies secured by lease portfoliosRegular counsel to various leasing and finance companies in connection with capitalization and funding transactions that include warehouse and term securitizations, lines of credit, sub debt borrowings and other equity infusionsRepresentation of mortgage REIT in connection with tax structuring, disclosure and tax opinions for the only two private label mortgage securitization transactions closed since 2008Representation of various mortgage finance companies as fund sponsors in connection with tax structuring, disclosure and tax opinions for investment funds investing in undervalued mortgage backed securities and distressed mortgage loan assetsRegular tax counsel to mortgage REITs with respect to their ongoing REIT qualification requirements, equity offerings and investment transactionsRecent Publications & PresentationsAuthor, “Historic Boardwalk Hall - Tax Court Focuses on ESD and Partnership Issues in Tax Credit Transactions”, Journal of Pass-Through Entities, 2011 (upcoming edition) Author, “Mortgage REITs-Pruning Portfolios and Prohibited Transaction Taxes”, Real Estate Taxation, 2010 (Volume 37, No. 4) Panelist, “Capital Markets Update and Funding Strategies Today”, at IMN/ELFA’s 9th Annual Investors Conference on Equipment Finance, March 2010Panelist, “Off Balance Sheet Accounting Changes: FAS 166 and 167, joint presentation with Ernst and Young, July 2009EducationNew York University School of Law — LL.M., Taxation, 1985University of Pittsburgh School of Law — J.D., cum laude, 1984University of Pittsburgh — B.A. Economics, summa cum laude, 1981