Shiukay Hung is Co-Chair of DLA Piper’s National REIT Tax Practice and a partner in DLA Piper's Investment Management and Real Estate Capital Markets Practice resident in the New York office. His primary focus is the real estate industry and particularly REITs (e.g., private REITs, public non-traded REITs/NAV REITs, US listed REITs, and Singapore listed REITs). Shiukay is recommended by Chambers USA 2023 and Legal 500 United States 2023 as a leading lawyer.
Drawing upon his experience as a lawyer in Canada and Asia, Shiukay is particularly sensitive to the tax considerations of non-U.S. investors. Shiukay is experienced in the acquisition, disposition and operation of real estate assets through fund, REIT and joint venture vehicles and has provided extensive advice on such matters to sovereign wealth funds, foreign pension funds, and other non-U.S. investors.
With over 15 years of experience, both as an in-house attorney and in private practice, Shiukay provides clients with practical advice on complex transactions that draws on his deep industry knowledge. He is actively involved in bar associations and industry groups including the Real Estate Round Table, the Institute for Portfolio Alternatives (IPA), and the National Association of Real Estate Investment Trusts (Nareit). He is a frequent legal commentator and has spoken before various audiences and media outlets including Bloomberg, Law360, SS&C, the American Bar Association, Tax Notes, the American Institute of CPAs, the Harvard Law School Association of New York City, Strafford, the Private Equity Law Report, and the Tax Executives Institute. He has also written for LexisNexis and the Real Estate Finance Journal.
- Represented a non-US pension fund in its $0.5B acquisition and related financing of a life science building portfolio in California from a US real estate private equity fund
- Represented a non-US pension fund in its $2B sale of an office building in New York to a Fortune 500 company
- Represented a non-US pension fund in its programmatic joint venture for the acquisition, financing and development of $1B of industrial outdoor storage/service facilities throughout the US
- Represented a US real estate private equity fund in its sale and equity and debt recapitalization of a portion of its $1B development of a mixed-use development in Boston
- Represented a non-US fund sponsor in its $300 million acquisition of a residential building in New York City through a privately-held REIT
- Represented a non-traded public REIT in its $4B acquisition by a US real estate private equity fund
- Represented several US sponsors in their launch of NAV REITs
- Ongoing representation of REITs listed on the Singapore Exchange (SGX) that own a portfolio of US real estate
- Harvard Law School, LL.M.
University of British Columbia, J.D., Wesbrook Scholar
University of British Columbia, B.Sc., Honors
Shiukay is recommended by Chambers USA 2023 and Legal 500 United States 2023 as a leading lawyer.
- Chambers USA
- Band 3, Nationwide REITs: Tax (2023)
- Legal 500 United States
- Leading Lawyer, REITs (2023)
- Recognized, Real Estate Investment Trusts (REITs) (2022 - 2023)
- "Shiukay is a very bright tax attorney in the REIT space."
- "He is very easy to work with, technical and practical."
Legal 500 United States
- "Shiukay has years of experience and great insights in dealing with REITs. He is a deep thinker that was always willing to help solve difficult questions, and constantly producing publication to help clients and peers navigate complex REIT rules. I have in many occasion inquired Shiukay on various issues I have encountered in transactions involving REITs and have always be very grateful for Shiukay's advice."
- Shiukay is "top-notch in tax knowledge, razor-sharp in thinking, and is able to explain tax issues to you in such a way that makes you feel you're smarter than you actually are."
- "The DLA REIT practice in NY is anchored by Shiukay Hung who is one of the premier REIT tax practitioners in the country. He is practicable, easy to work with and given his extensive REIT knowledge finds solutions to problems before they even arise."
- "I enjoy working with Shiukay Hung who is experienced and practical."
- Co-author, "REIT Tax Resource Center" DLA Piper National REIT Tax Practice
- Co-author, "Understanding REIT tax: FAQs," DLA Piper Alert, August 28, 2023
- Co-author, "Ending tax breaks for massive sovereign wealth funds? Practical observations about the Wyden bill," DLA Piper Alert, August 9, 2023
- Co-author, "New Real Estate Investment Trust Tax Guidance on Parking, Amenity Space and Modern Tenant Services," Thomson Reuters, Summer 2023
- Co-author, "IRS provides favorable guidance on REIT tax treatment of transferable renewable energy credits for rooftop solar panels and electric vehicle charging stations," DLA Piper Alert, July 6, 2023
- Co‐author, "REIT Tax News," DLA Piper Alert, July 2023
- Co-author, "IRS says regularly traded stock exception to FIRPTA applies at the partnership/fund level," DLA Piper Alert, June 1, 2023
- Co‐author, "REIT Tax News," DLA Piper Alert, April 2023
- Co-author, "New REIT Tax Guidance on Parking, Amenity Space and Modern Tenant Services," DLA Piper Alert, February 23, 2023
- Co-author, "IRS Issues Proposed Regulations Impacting the Determination of Domestically Controlled REIT Status," LexisNexis Practical Guidance, December 29, 2022
- Co-author, "What Are NAV REITs? Answers to Some Frequently Asked Questions," The Real Estate Finance Journal, Fall 2022
- Co-author, "IRS Partially Revokes Previously Issued Private Letter Ruling on Percentage Rent," LexisNexis Practical Guidance, March 2022
- Co-author, "To Rely or Not to Rely? Sub-Regulatory Tax Guidance in Turbulent Times," Tax Executive, January/February 2021
- Co-author, "Final Regulations Clarify the Definition of 'Real Property' Under the REIT Rules," the Real Estate Finance Journal, January 2017
- Speaker, "DC REITs: To Look Through or Not to Look Through," SS&C, June 2023
- Panelist, “Advanced Tax Strategies in Structuring Private Equity and Real Estate Investment Funds: Balancing Competing Interests,” Strafford, March 2022
- Moderator, "Important Trends in COVID-Era M&A Transactions," Tax Executives Institute, March 2021
- Moderator, "2021 Tax Roundtable: Changes in Tax Laws Under the Biden Administration," Harvard Law School Association of New York City, February 2021
- Moderator, "Select 2020 Federal Income Tax Developments and Outlook for 2021," Tax Executives Institute, December 2020
- Moderator, "Every 10 Years I Have to Relearn Section 382," Tax Executives Institute, November 2020
- Moderator, "To Rely or Not to Rely – That is the Question – Subregulatory Guidance in Turbulent Times," Tax Executives Institute. October 2020
- Panelist, "IRS & Treasury Panel: Partnership Reporting (Inbound)," American Bar Association, August 2020
- Panelist, "IRS & Treasury Panel: Partnership Reporting (Outbound)," American Institute of CPAs, August 2020
- Moderator, "COVID-19 Related Tax Considerations for the Real Estate Industry," Harvard Law School Association of New York City, April 2020
- Panelist, "What (Not So) Crazy Rich Asian Americans Need to Know About Qualified Opportunity Zones," National Asian Pacific American Bar Association, November 2019
- Panelist, "What the World of Accountancy Needs to Know About Blockchain and Cryptoassets," Wall Street Blockchain Alliance, November 2017
- "NYSBA Tax Section Report Addresses Proposed Regs on Transfer of Credits," Tax Notes, August 2023
- "DLA Piper lawyers and practices ranked in this year's Legal 500 US guide," June 2023
- "DLA Piper lawyers and practices ranked in Chambers USA 2023," June 2023
- "ABA Tax Section Critiques Proposed Regs on Foreign Government Exemptions," Tax Notes, February 2023
- "Notable Tax Provisions and Circumstances to Weigh to Optimize Treatment of Non-U.S. and Tax Sensitive Investors (Part Two of Two)," Private Equity Law Report, July 12, 2022
- "Notable Tax Provisions and Circumstances to Weigh to Optimize Treatment of Non-U.S. and Tax Sensitive Investors (Part One of Two)," Private Equity Law Report, June 28, 2022
- "More Than A Dozen Firms Guided Top Q1 Real Estate Deals," Law360, April 2022
- "Simpson, DLA Steer $3.7B Blackstone-Resource REIT Deal," Law360, January 2022
- "The Daily Docket: Industry Moves," Reuters, September 2021
- "Laterals, Moves, In-house," Bloomberg Law, September 2021
- "Shiukay Hung joins DLA Piper's Finance practice in New York," September 2021
- "Late Feedback On Partnership Forms May Lose Out, Official Says," Law360, August 2020
- "Cooperation May Be Key to International Partnership Form Changes," Tax Notes, August 2020
- "IRS Will Consider Late Comments on New Partnership Forms," Bloomberg, August 2020
- "Government Explains Changes to International Partnership Forms," Tax Notes, August 2020
- "New Partnership Tax Forms May Cause Duplication of Work," Bloomberg, August 2020
- "Wyoming Could Serve As Cryptocurrency Tax Bellwether," Law360, May 2018
- "More Than A Dozen Firms Guided Top Q1 Real Estate Deals," Law360, April 2022
Memberships And Affiliations
- Board Member, Harvard Law School Association of New York City
- Member, Real Estate Roundtable, Tax Policy Advisory Committee
- Member, Institute for Portfolio Alternatives (IPA), Tax Policy Task Force
- Member, Tax Club
- Member, New York Committee of Realty Trust Tax Lawyers
- Member, National Association of Real Estate Investment Trusts (Nareit), Federal Tax Subcommittee
- Member, American Bar Association, Section of Taxation
My latest insights
IRS rules subsurface carbon dioxide storage payments are qualifying REIT income
14 September 2023 .4 minute read