Partner, Transactional Tax Practice
CurrentGerald has significant experience advising clients on all aspects of avoiding the creation of a taxable presence in the United States, mitigation of effectively connected income, utilization of tax treaties and favorable law to eliminate incidences of the federal excise tax on insurance premiums, and compliance with withholding and reporting obligations under FATCA. In addition, he regularly advises clients on the specialized rules applicable to insurance companies under the controlled foreign corporation and passive foreign investment company regimes, and how to take advantage of statutory safe-harbors under these two regimes.Gerald has also represented parties engaging in mergers and acquisitions (both tax-free and taxable), joint ventures and partnerships, multi-jurisdictional acquisitions and dispositions, leverage buyouts and bankruptcy reorganizations. Working with cross-practice teams, Gerald advises on identifying opportunities to add value through effective tax planning both before and after a transaction.Gerald has extensively advised bankers and investment bankers on the tax aspects of capital market transactions, including structures designed to legally reduce the cost of funds or enhance yield in the United States and abroad.
