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Christopher Mangin, Jr.
Christopher Mangin, Jr.
Partner — Tax
Partner — Tax

Christopher Mangin, Jr.

Christopher Mangin, Jr.
Washington, D.C.

2200 Pennsylvania Avenue NW
Suite 500 West
Washington, D.C. 20037

start quote symbolI enjoy the opportunity to help clients comprehend and navigate the tax aspects of achieving their business goals in a way that is understandable, practical, and commercial.end quote symbol
Christopher Mangin, Jr.

Experience Highlights

  • Co-led ABA Section of Taxation’s comment letter on Treasury and IRS’s proposed regulations under Sections 897 and 892 regarding issues affecting foreign investment in U.S. real estate

  • Bluerock Residential Growth REIT as special tax counsel in its $3.6 billion acquisition by affiliates of Blackstone Real Estate and the spin-off its single-family rental business into Bluerock Homes Trust, a newly formed REIT

  • DigitalBridge in its acquisition of a controlling stake in Vertical Bridge Holdings, the largest private owner and operator of wireless communications infrastructure in the U.S.

  • WPT Industrial Real Estate Investment Trust in its $3.1 billion sale to Blackstone Real Estate Income Trust, Inc.

  • Data Foundry, Inc., a carrier-neutral colocation and data center provider, in its $420 million sale to Switch, Inc.

  • Jera Asset Management and Setzer Properties in formation of a joint venture with the Australian Superannuation Pension Fund, including the roll-up of a seed portfolio of net leased transportation terminal and logistics properties

  • Alpine Income Property Trust, Inc. in its $143 million initial public offering of common stock

  • CTO Realty Growth, Inc. in its conversion to a REIT

  • NorthStar Realty Europe Corp. as special tax counsel in its merger with Core Paneuro 2019 13 Sarl

  • The Special Committee of the Board of Directors of Owens Realty Mortgage, a specialty finance REIT, in its $200 million merger with Ready Capital Corporation, a real estate finance company

  • Oncor Electric Delivery Company in its $2.2 billion acquisition of InfraREIT

  • CYS Investments, an agency mortgage REIT, in its $1.475 billion merger with Two Harbors Investment Corp., a leading hybrid mortgage REIT

  • TPG RE Finance Trust, Inc. in its $233 million initial public offering and multiple follow-on offerings

  • TPG RE Finance Trust, Inc., as special tax counsel, in its $932.4 million collateralized loan obligation (CLO)

  • NorthStar Realty Finance in its approximately $16 billion combination with NorthStar Asset Management Group and Colony Capital in an all-stock merger of equals

  • Global Medical REIT Inc. in its $150 million initial public offering of common stock and all of its subsequent capital markets transactions including five follow-on underwritten public offerings with an approximate transactional value of $343 million; three ATM offerings with an approximate transactional value of $250 million; and its $77 million public offering of Series A cumulative redeemable preferred stock

  • Issuers and underwriters in public and private equity and debt offerings by REITs

  • Targets and acquirors in tax-deferred and taxable mergers and acquisitions, reorganizations, restructurings, and dispositions, including tax-free spin-offs under Section 355 of the Internal Revenue Code

  • REITs, including hotel REITs, equity REITs, healthcare REITs, commercial mortgage REITs, residential mortgage REITs, and hybrid REITs, on investment structuring, including joint ventures with operators, taxable REIT subsidiary (TRS) structures, investments in funds, mezzanine loans, and distressed debt

  • Buyers and sellers on the tax-efficient purchase, sale, and recapitalization of real estate and real estate-owning entities

  • Tax planning on the formation of REITs and rollup transactions involving REITs and umbrella partnership real estate investment trusts (UPREITs) as well as DownREIT structuring 

  • Formation and restructuring of real estate joint ventures using partnerships and limited liability companies

  • Clients in connection with private letter rulings (PLRs) submitted to the Internal Revenue Service

  • Matters arising under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA)


  • University of Virginia School of Law, J.D., 2006 (Executive Editor, Virginia Tax Review)
  • Wake Forest University, M.S., Accounting, 2000
  • Wake Forest University, B.S., Accounting cum laude, 2000
  • Chambers USA, REITs: Tax (Nationwide), 2019–2024
  • Legal 500 U.S., Real Estate: REITs, 2019–2024; Tax: International Tax, 2020; Tax: US Taxes: Non-Contentious, 2020, 2022-2024
  • The Best Lawyers in America© (BL Rankings, LLC), (Richmond): Mergers & Acquisitions Law, 2023 and 2024; Leveraged Buyouts and Private Equity Law, 2024
  • Member: American Bar Association, Tax Section
  • Member: National Association of Real Estate Investment Trusts
  • Virginia
  • District of Columbia
  • “Anatomy of a Real Estate Joint Venture,” V&E REIT Series CLE, June 28, 2021 (co-speaker)
  • “Impact of Final Carried Interest Regulations on REITs and Real Estate Funds,” V&E REIT Series CLE, March 3, 2021 (co-speaker)
  • “Why Do Property REITs Have Operating Partnerships,” REIT Series, V&E New York Office, May 28, 2019 (speaker)
  • “Partnership Tax Issues,” Nareit REITwise 2019 Law Accounting Finance Conference, March 27, 2019 (speaker)
  • “Qualified Opportunity Funds, Real Estate, and REITs,” REIT Series, V&E New York Office, February 20, 2019 (speaker)
  • “REIT Internalization Transactions,” REIT Series, V&E New York Office, October 30, 2018 (panelist)
  • “Advising the Board on Crisis Management,” CRE.Converge 2018, October 17, 2018 (panelist)
  • “REITs and Infrastructure Investment,” V&E New York Office, April 18, 2018 (presenter)
  • “TCJA Impacts on REITs and REIT Transaction Structures,” V&E New York Office, February 15, 2018 (speaker)
  • “IRS Issues Guidance on Elective Cash Stock Dividends by REITs,” V&E REIT Update E-communication, August 16, 2017 (co-author)
  • “REIT Tax Planning,” REITWise, La Quinta, California, March 24, 2017
  • “New Disguised Sale Guidance Presents Major Change for Partnership Transactions,” V&E Tax Update E-communication, October 4, 2016 (co-author)
  • “Energy REITs and Real Estate MLPs,” V&E Energy Series, Houston, Texas, July 13, 2016