Stewart McMichael

Counsel

Stewart McMichael is a seasoned tax attorney with more than 20 years of experience in domestic and international taxation. He specializes in tax equity financing, real estate transactions, and cross-border tax matters, advising clients across renewable energy, real estate, private equity, and global markets.

He has structured and monetized over $200 million in tax incentives spanning renewable energy, low-income housing, new markets, R&D, and film. His expertise includes partnership flips, sale-leasebacks, inverted and pass-through leases, with recent focus on transactions under the Inflation Reduction Act of 2022.

Stewart advises on complex partnership and corporate taxation, including multi-tiered structures, Section 704(b) & (c) allocations, consolidated returns, and taxable and tax-free M&A. His international work covers TCJA, GILTI, PFICs, foreign tax credits, cross-border M&A, and treaty compliance, along with FATCA, FBAR, and international reporting requirements.

As founder of Grand Army Managed Enterprises, he raised $500 million in equity financing and syndicated $1 billion from top financial institutions. Under his leadership, the firm achieved or exceeded target IRRs on 70+ projects, repatriating more than $2.6 billion in earnings.

Stewart began his career with Orrick, Herrington & Sutcliffe LLP and O’Melveny & Myers LLP, counseling financial institutions and private equity firms on securitization, structured finance, and international tax. He is a frequent lecturer and author on tax equity, partnership taxation, and international tax compliance.