Philip Wright’s practice concentrates primarily on advising clients with regard to the domestic and international tax aspects of corporate acquisitions, mergers, dispositions, securities offerings and related tax matters; including structuring, negotiation, and documentation in respect of same. He also advises clients in controversy matters with the Internal Revenue Service principally regarding issues involved in acquisitions and divestitures.

Mr. Wright serves as an adjunct professor in the Masters Tax Program at Washington University Law School where he has taught both Corporate Reorganizations and Federal Taxation of Partnerships. He has also served as adjunct professor at Fontbonne University where he taught Advanced Corporate Tax—Consolidated Tax Returns. He frequently writes and speaks on tax issues involved in merger and acquisition transactions. His prior professional experience includes practice as a certified public accountant with a Big Four accounting firm. He is a fellow of the American College of Tax Counsel. He is listed in Best Lawyers in America and in Missouri & Kansas Super Lawyers.

Bar and Court Admissions

Missouri, 1985

District of Columbia, 1983

New York, 1983

United States Tax Court

Education

New York University, LL.M., 1985

Georgetown University, J.D., cum laude, 1982

University of Missouri-Columbia, B.S., magna cum laude, 1979

Publications

• Author, "To Err Is Human; to Rescind, Devine," Vol. 90 No. 3 Taxes 75 (March 2012)
• Co-Author, "Disregarded Entities – Issues and Opportunities," Practising Law Institute, Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances-2011, February 2012
• Co-Author, "Acquisitive D Reorganizations," Practising Law Institute, Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations and Restructuring-2011, July 2011
• Co-Author, "Disregarded Entities in Corporate Transactions," Practising Law Institute, Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations and Restructuring-2011, June 2011
• Author, "Step-Transaction Doctrine in Corporate Reorganizations," Panel Publishers, Mergers and Acquisitions, The Monthly Tax Journal, February 2002
• Author, "Proposed Regulations Impact Disregarded Entity Mergers," Panel Publishers, Mergers and Acquisitions, The Monthly Tax Journal, August 2000
• Author, "Disregarded Entities: Planning Opportunities and Pitfalls in Domestic Corporate Transactions," 24 J. Corp. Tax’n 341, Winter 1998

Speeches and Seminars

• "Mergers and Acquisitions Tax Primer," American Law Institute/American Bar Association, Corporate Taxation, March 28-30, 2012

• Co-Speaker, “Interesting Partnership Transactions of the Past Year,” Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures, & Other Strategic Alliances, Chicago and San Francisco 2012

• Co-Speaker, "Interesting Transactions of the Past Year," Practising Law Institute, Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings Los Angeles, December 2011
• Rescission, University of Chicago, 64th Tax Conference, November 2011
• Understanding the Subpart F Provisions CITE Conference, U.S. International Tax Reporting & Compliance, St. Louis, July 2009
• Co-Speaker, “Internal Restructurings – Selected Issues,” American Bar Association, 2008 Midyear Meeting, January 2008
• Co-Speaker, “Unwinding the U.S. Sandwich,” American Bar Association, 2007 Joint Fall Meeting, September 2007
• "Understanding the Rules for Computing Foreign Exchange Gain (Loss)," CITE Conference, U.S. International Tax Reporting & Compliance, April 2007
• Co-Speaker, "When Do Business Transactions Require Valuations?," Southern Federal Tax Institute, September 2006
• "Transfer of Stock and Assets to a Foreign Corporation," CITE Conference, U.S. International Tax Reporting & Compliance, July 2006
• "Tax Considerations in Structuring Acquisitions, Familiar Concepts and New Twists," Heart of America Tax Institute, 42nd Annual Tax Conference, November 2005
• "Proposed Regulations on Insolvent Corporate Reorganizations, Tax-Free Liquidations, and Tax-Free Incorporations – What You Need to Know," ABA Section of Taxation, CLE Teleconference, May 2005
• "Consolidated Entities, Advance Topics," RSM McGladrey, 2004 Annual Tax Specialists’ Conference, June 2004
• "Tax Issues for Insolvent and Financially Troubled Corporations," Twentieth Texas Federal Tax Institute, June 2004
• "U.S. Tax Consequences – Disposition of an Interest in a Foreign Entity," CITE Conference, U.S. International Tax Reporting & Compliance, July 2002
• "Preferred Stock in Corporate Transactions," Seventeenth Texas Federal Tax Institute, June 2001
• "Corporate Distributions in Connection with Acquisitions and Dispositions," Fifteenth Texas Federal Tax Institute, June 1999
• "Consolidated Group Joint Ventures, LLCs and Disregarded Entities," Tax Executives Institute, Inc., November 1998
• "The Disregarded Entity," Forty-Seventh Tulane Tax Institute, October 1997

Professional Affiliations

• American Bar Association Tax Section – Corporate Committee, Chair, 2005-2006
• New York State Bar Association – Section on Tax, Committee on Corporations and Committee on Reorganizations
• Washington, D.C. Bar Association – Tax Section
• Missouri Bar Association