Franziska Hertel practices as an associate in the tax group, focusing on matters involving tax-exempt organizations, transaction structuring and analysis, and partnership tax matters. Franziska regularly advises colleges and universities, private foundations and healthcare organizations on a broad range of issues, including transactions with for-profit and non-profit partners, internal structuring and tax controversy matters. Franziska also provides counsel on a variety of tax matters relating to the structuring and operational issues of investment funds, their portfolio investments and their sponsors, including with respect to cutting-edge investments such as cryptocurrencies.
Franziska also maintains an active pro bono practice, focusing on immigration matters. In 2017, Franziska co-founded AlienAid, inc., a 501(c)(3) non-profit organization dedicated to helping international students navigate the challenges that come with their status in the United States, and currently serves as CEO of that organization.
Franziska joined Ropes & Gray in 2014. During law school, Franziska served as Articles Editor of the Columbia Law Review. Prior to joining Ropes & Gray, Franziska worked on matters of tax policy at the New York Attorney General’s Office.
- Advised fund sponsor on structuring of the first exchange-traded cryptocurrency fund
- Represents university endowments and leading charitable foundations in their investments in U.S. and international private equity and venture funds
- Advised on the sale of The Weather Company's B2B, mobile and cloud-based web properties to IBM
- Provided tax counsel to multiple healthcare systems in affiliation transactions with both non-profit and for-profit parties
- Assisted prominent tax-exempt organizations in internal restructuring transactions, including representing them in state Attorneys General and court proceedings
- Represents flagship state university systems in IRS audit and appeals proceedings
- Regularly counsels leading mutual funds and their independent trustees, including the State Street Global Advisors Funds, Putnam Funds and Voya Funds, on issues surrounding fund formation, reorganization and tax compliance.
- Quoted, “IRS Says Cryptocurrency Revenue Ruling ‘Speaks for Itself,’” Tax Notes (March 2, 2020)
- Co-author, “UBTI ‘Silo’ Notice: Interim Rules and Potential Future Guidance,” Tax Notes (October 15, 2018)
- James R. Brown and Franziska Hertel, “Virtual Currencies and the Commodity Trading Safe Harbor,” Tax Notes (June 18, 2018)
- Franziska Hertel, “Qui Tam for Tax?: Lessons from the States,” 113 Columbia Law Review 1897 (2013) (awarded First Prize in National Tannenwald Competition for Excellence in Tax Scholarship)
- Panelist, “Responding to a Mess(ier) Crypto Tax Landscape,” Virtual 21st Annual U.S. and Europe Tax Practice Trends Conference (March 22, 2021)
- Co-panelist, “Year in Review,” Massachusetts Continuing Legal Education - 22nd Annual Nonprofit Law Conference (March 18, 2021)
- Chair, “Taxation of Cryptocurrencies,” 48th Annual Conference of the USA Branch of the International Fiscal Association (February 28, 2020)
- Franziska Hertel and Julie Hogan Rodgers, “Initial Coin Offerings and Virtual Currencies: Tax Considerations for Issuers and Investors,” Boston Bar Association (December 13, 2018)
- JD, Columbia University School of Law, 2014; James Kent Scholar; Ruth Bader Ginsburg Prize; Pauline Berman Heller Prize; articles editor, Columbia Law Review
- BA (Government), summa cum laude, Dartmouth College, 2011; Salutatorian; Phi Beta Kappa
Admissions / Qualifications
- Massachusetts, 2014
- The Best Lawyers in America – Ones to Watch (2021-2023)