Orrick attorneys authored an article, titled “Proposed Regulations Under §385 Classifying Interests in a Corporation,” addressing Section 385 regulations proposed by the Internal Revenue Service and the U.S. Treasury Department to address the excessive use of debt to reduce the U.S. tax base. The article was published in the Tax Management International Journal and is available here.
Michael Rodgers is a Managing Associate in the Houston office who specializes in cross-border tax planning.
- Provided advice and analysis to Fortune 100 multinational oil and gas company in connection with proposed international tax legislation
- Provided tax planning and structuring advice for billion dollar private equity fund in connection with various acquisitions of portfolio companies throughout Europe and South America
- Advised global high-tech conglomerate as to tax planning, withholding tax, and debt financing considerations as a means to facilitate internal corporate restructuring
- Served as U.S. tax counsel to start-up Mexican company looking to expand operations into the United States in a tax-efficient manner
- Assisted numerous U.S. individual taxpayers with issues related to expatriation tax, residency analyses, and foreign bank account reporting obligations
- Served as U.S. tax counsel for U.S. citizens and small businesses investing in both Europe and Asia
- Served as U.S. tax counsel for mid-sized foreign fund engaged in commodities trading in the United States
- Provided international tax structuring advice and technical tax analysis to $200 billion global services fund engaged in tax equity investments involving renewable energy projects