Tom focuses on federal and state corporate income tax matters. A member of Husch Blackwell’s Technology, Manufacturing and Transportation team, he analyzes and advises clients on the tax implications of corporate transactions such as mergers, acquisitions, joint ventures, debt and equity restructurings, financings and securities offerings. Tom drafts and negotiates tax-related provisions in agreements and other documents related to such transactions. He represents clients in transactions involving corporate, partnership, and international tax matters. He is experienced in assisting both U.S. and non-U.S. based clients in their cross-border transactions, including advising U.S. companies with respect to the subpart F rules, the utilization of foreign tax credits and the tax-efficient repatriation of earnings, and advising non-U.S. companies in connection with structuring their U.S. investments and business activities. Tom also has experience with the tax aspects of workouts, including issues related to the restructuring and retirement of indebtedness. He has also specifically addressed Code Section 385 issues and has experience in defending against IRS attacks on tax-efficient structures, in both international and domestic tax contexts. When tax disputes arise, Tom diligently represents clients in federal and state tax audits and administrative appeals, as well as in tax litigation. His tax experience includes:
Tom also has particular expertise with real estate investment trusts (REITs). He advises public REIT clients on tax matters in connection with securities offerings and corporate transactions including reviewing and drafting tax disclosures for offering memoranda, prospectuses and proxy statements. He has provided tax advice to a utility in connection with its potential REIT conversion; advised on the spin-off of a REIT and subsequent public offering of the REIT’s shares; and advised a public REIT in connection with its $1 billion acquisition of a portfolio of properties.
Before joining Husch Blackwell, Tom served as Counsel in the Chicago office of Jones Day.