Michael Rodgers

Senior Associate


Read full biography at www.orrick.com

Michael Rodgers is a Senior Associate in the Houston office who specializes in cross-border tax planning.

Michael has devised numerous tax-efficient structuring plans for a wide variety of public and private clients, including private equity funds and strategic buyers involved in both domestic and cross-border mergers, acquisitions, spinoffs, restructurings and other transactions. Additionally, Michael has assisted both individual clients and businesses with “inbound” issues, relating to the tax consequences and best practices associated with foreign investment and business activities in the United States, as well as “outbound” issues, involving Americans investing or doing business abroad. Locally, Michael also serves many of Houston’s energy sector clients with various technical tax issues.
  • 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

Posts by: Michael Rodgers

Proposed Regulations Under §385 Classifying Interests in a Corporation

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.