Rafi Mottahedeh is a partner in the Firm’s Tax Group.

Rafi advises investment fund sponsors on the federal income tax matters relevant to all aspects of their business. His practice includes advising clients on fund formation and structuring, sponsor liquidity and minority investment transactions, fund- and sponsor-level tax considerations arising from investments, mergers and acquisitions, and sponsor-level economic and tax planning and structuring.

Rafi has experience advising sponsors and investors on the tax considerations relevant to a wide variety of asset strategies, including private equity, venture capital, hedge funds, secondaries, real estate, crypto, credit, and distressed and special situations. He has advised asset managers with less than $50 million AUM to over $50 billion AUM with operations and investments in more than a dozen countries.

Rafi also plans and structures other complex business transactions, including mergers and acquisitions, joint ventures, and venture capital investments for both investment funds and publicly traded companies. Furthermore, he regularly advises companies on complex partnership tax and U.S. international tax questions, including Subpart F, foreign tax credit planning, and treaty planning. His dexterity with both partnership tax and U.S. international tax allows him to advise clients on unique strategies from a holistic perspective.

Prior to joining Shartsis Friese, Rafi was at a large international law firm and later worked as tax counsel at a major U.S. multinational company where he served as global tax lead for a financial services business unit.

Rafi maintains an active pro bono practice. Outside of work, he is an avid marathon runner and triathlete.

Mr. Mottahedeh’s representative clients include:

  • Alkeon Capital Management, LLC
  • Artis Ventures Management L.P.
  • Care Equity
  • Community Investment Management, LLC
  • EcoR1 Capital, LLC
  • Prana Investments, Inc.
  • Right Side Capital Management LLC
  • SQN Investors LP
  • Stonepine Capital Management, LLC
  • Universa Investments L.P.
  • Valiant Capital Management, L.P.
  • Waste Connections, Inc.

Rafi is a prolific writer, speaker, and moderator on topics related to tax.  Recent speaking engagements include:

Moderator, “Lessons Learned From the Cross Refined Coal Case,” American Bar Association Section of Taxation, 2024 Midyear Tax Meeting, January 18, 2024.

Moderator, “Recent Inbound Tax Cases & Other Guidance,” American Bar Association Section of Taxation, 2024 Midyear Tax Meeting, January 18, 2024.

Panelist, “What Profits? Gross Income Allocations for Carried Interest/Performance Allocations in Private Funds,” American Bar Association Section of Taxation, May Tax Meeting, May 4, 2023.

Panelist, “Movin’ on Up: Is indexing basis for inflation worth a fresh look?”, American Bar Association Section of Taxation, May Tax Meeting, May 14, 2022.

Panelist, “U.S. Shareholder Basis in Foreign Corporations Post-Tax Reform,” American Bar Association Tax Section, 2019 Mid-Year Meeting.

ABA Section of Taxation Council Director, 2023-2026

ABA Section of Taxation Committee Chair, 2020-2022

ABA Section of Taxation Nolan Fellow

Albert E. Jenner Pro Bono Award

Diversity Mentor, Loretta Collins Argrett Fellowship

Member, National LGBT Bar Association