Three from Bryan Cave Address ABA Section of Taxation Midyear Meeting
February 27, 2012
The annual ABA Section of Taxation Midyear Meeting brings together many of the country’s leading attorneys and government officials to discuss the latest federal tax policies, initiatives, regulations, legislative forecasts and planning ideas. Held recently in San Diego, Calif., this year’s meeting included key contributions from three Bryan Cave attorneys.
St. Louis Partner Dan White moderated a panel on tax opinions in publicly registered transactions. The panel explored guidance related to the tax opinion practice, including SEC Staff Legal Bulletin 19 (Oct. 14, 2011) related to tax opinions in publicly filed transactions and Canal Corp. v. Comm’r
as it relates to the benefit clients receive from tax opinions and how that could affect the practice of tax law from the perspective of outside advisers.
White’s practice focuses primarily in corporate and partnership tax planning, including acquisitions, mergers, reorganizations, spin-offs and restructuring transactions. He regularly represents public and private operating companies as well as venture capital and private equity funds.
New York Counsel Alan Appel addressed tax regulations and other issues that arise when non-U.S. persons invest in the U.S. through partnerships in “Hola, Ni Hao, Shalom – Say Hello to Your Foreign Partner.” His panel outlined a number of issues arising when non-U.S. persons invest through one or more partnerships, including Section 1446 issues, the recently proposed Section 892 regulations and partnership-specific FIRPTA issues.
Appel chairs the U.S. Activities of Foreigners and Tax Treaties (USAFTT) Committee of the ABA Tax Section. He focuses his practice in international and domestic tax planning involving taxation of mergers and acquisitions, partnerships, joint ventures, limited liability companies and tax controversy matters.
Denver Counsel Tim Glasgow joined a panel discussion on the basics of Qualified S Corporation Subsidiaries (QSubs) and specific issues involving QSubs as disregarded entities for federal purposes.
Glasgow advises entities and individuals on the federal, state and local tax consequences of a wide variety of matters including mergers and acquisitions, debt and equity offerings, joint ventures and restructurings of corporations and partnerships. In addition, he has worked on several tax disputes and has extensive estate planning experience.
for more information on the ABA Section of Taxation Midyear Meeting.