Government Experience

  • Officer, the U.S. Army Reserve and previous service with the New York Army National Guard
  • National Office of the Office of Chief Counsel, IRS

Bar Admissions

  • New York

Court Admissions

  • U.S. Tax Court


  • LL.M., New York University School of Law, 2002
  • New York University School of Law, 2000
    Associate Editor, Moot Court Board
  • B.A., summa cum laude, City University of New York, Hunter College, 1995


  • Member, International Fiscal Association, US Branch
    Joint General Reporter, Investment Funds topic, London Congress 2019

    New York State Society of CPAs
    Non-CPA Associate Member


  • Korean
  • Spanish
T +1 212.503.0695
F +1 212.307.5598

Sung H. Hwang


Sung Hyun Hwang is a partner in Venable’s Tax and Wealth Planning practice. He focuses on the full spectrum of business tax law, from complex structured financial products to multi-partner business joint ventures.

Mr. Hwang has significant experience in domestic and cross-border transactions involving real estate partnerships and funds, private equity funds, hedge funds, asset managers, family offices, and financial institutions. Mr. Hwang also has significant experience in the tax credit space, including the energy-based tax credit area. He frequently represents clients before the IRS and state and local tax authorities in connection with tax ruling requests and audits, as well as in litigation in the U.S. Tax Court.

In addition to his legal career, Mr. Hwang is an officer in the U.S. Army Reserve and previously served with the New York Army National Guard. In 2008, he deployed to Afghanistan with a New York Army National Guard infantry unit as part of the Operation Enduring Freedom.

Significant Matters

  • Represented and structured mezzanine debts for a mortgage REIT client.
  • Represented client in the creation of a privately-held REIT for two institutional investors to acquire an office property in Manhattan.
  • Represented client in the structuring of a hybrid shopping mall/hotel REIT.
  • Represented a solar energy developer in structuring and negotiating joint ventures with institutional investors.
  • Represented a U.K.-based hedge fund in its relocation to the Cayman Islands.
  • Represented a logistics management company in an initial public offering of its stock through an "UP-C" structure.
  • Represented a New York City real estate developer on the acquisition of a three-acre industrial site in Bushwick, Brooklyn, for development into a mixed-used office, retail, and restaurant property. The deal included the structuring of two joint ventures and financing from a NYC-based real estate financing firm.
  • Represented a Hong Kong-based asset management company in an investment in a joint venture to develop commercial real estate in the United States.
  • Represented an investment manager in the formation of a domestic hedge fund that will invest in undervalued situations across a broad range of asset classes, industries, and markets by utilizing its own proprietary fundamental research, sourcing, and diligence methodologies.
  • Represented a New York-based investment manager in a joint venture with an Argentine investment advisor in establishing a private investment fund investing in Argentine public equities, debt, private equity, and real estate.
  • Represented a development stage life sciences company in its reverse triangular merger with a public company.
  • Represented an SEC-registered investment adviser in the restructuring of its Cayman Islands master-feeder fund complex to reflect the addition of new share classes and changes to fee terms.
  • Represented a hedge fund in negotiating a seed investment by a large university endowment, restructuring terms of the existing fund vehicle to accommodate the seed investor, and converting the fund into a master-feeder structure.
  • Represented a hedge fund in the formation of a separate series that was formed to acquire $10 million of credit-linked floating rate notes issued by a large financial institution.
  • Represented an investment manager in the formation of a hedge fund that acted both as a fund-of-hedge funds and direct investor.
  • Represented a master-feeder hedge fund which invests opportunistically in a long-short balanced portfolio consisting primarily of U.S. equity securities.
  • Represented an investment advisor in the formation of a master-feeder hedge fund structure with a global investment strategy.
  • Represented a power tool maker in its successful sale to its publicly traded competitor.
  • Represented a leading provider of clinical software solutions in its acquisition by a leading private equity investment firm in a transaction valued at $195 million.
  • Represented a private equity fund in the acquisition from a large investment bank of senior mezzanine and first mortgage loans encumbering a property on Manhattan's Upper West Side.
  • Represented an international private investment bank regarding tax structuring, regulatory compliance, and risk mitigation issues for their outsourcing and employee sharing arrangements related to registering a U.S. broker dealer subsidiary.
  • Represented a hedge fund in its sale to a publicly held special-purpose acquisition company (SPAC) organized in the Cayman Islands.
  • Represented the trustee of a bankruptcy estate of a hedge fund in its bankruptcy workout.