International tax, restructuring, and mergers and acquisitions.

Developed and implemented efficient structuring alternatives for publicly traded Fortune 50 companies, privately held corporations, and foreign based multi-jurisdictional companies. Drafted, reviewed, and edited Circular 230 covered opinions concerning certain acquisitive and divisive transactions, including analysis of economic substance.Provided time-sensitive research and recommendations relating to various tax consequences associated with multi-jurisdictional M&A transactions, including acquisitive and divisive transactions, restructuring, and distribution planning. Reviewed various legal memoranda prepared by clients' counsel to determine U.S. and foreign tax treatment, including formation agreements, termination agreements, purchase and sale agreements, and inter-company debt instruments.Researched, drafted, and reviewed memoranda relating to certain Subpart F issues, treaty issues, FIRPTA matters, and other international tax issues.

Reviewed broad range of civil and criminal motions before the court and drafted summary judgment rulings.Performed on-the-spot research and analysis of legal theory and case law submitted to the court, and reviewed and edited opinions drafted by Judge Bowler.