|
|
|
 |
|
Biography
Ed's practice includes all areas of business income taxation, with emphasis on corporate and partnership taxation and international transactions. He chairs the International and Transactional Group of the firm's Tax Section. He also is a member of the firm's International, Structured Finance, and Electric Power Practice Groups.
Ed advises corporate and individual clients on the federal tax consequences of various transactions, including mergers and acquisitions; tax-free reorganizations; corporate spin-offs and other divestitures; partnerships; structured finance transactions; foreign operations, including cross-border joint ventures with non-U.S. partners; and inbound investment into the United States by non-U.S. investors.
|
|
|
Representative
Experience
- Represented an entertainment retail company in connection with its $1.5 billion tax-free split-off from its publicly-traded parent company
- Provided U.S. tax advice on the worldwide restructuring of the operations of a major U.S.-based company
- Served as lead U.S. tax counsel on the structuring of the worldwide operations of various U.S.-based multinational corporations
- Participated in tax planning and structuring for power projects in countries around the globe, including Argentina, Bolivia, Brazil, China, Colombia, Costa Rica, the Dominican Republic, Ecuador, El Salvador, Honduras, India, Mexico, Mozambique, Panama, Peru, the Philippines, South Africa, Trinidad and Tobago, Turkey, and the United Kingdom
- Served as the lead tax lawyer on a $2 billion cogeneration facility in Mexico involving investors from Canada, the United States, and Mexico
- Served as lead U.S. tax lawyer in $4+ billion acquisition of Canadian energy company using "exchangeable shares"
- Structured a proposed tax-free acquisition by an English company of a $2 billion U.S. subsidiary of a publicly held U.S. corporation
- Served as lead tax counsel to a major energy company in connection with its agreement to dispose of a major electric utility company
- Served as lead tax lawyer on multi-billion dollar oil field services merger
- Advised a U.S. corporation on a $250 million acquisition of a Canadian chemical operation
- Served as lead tax lawyer on various Eurobond offerings aggregating well over $2 billion, and various asset securitization transactions totaling more than $1 billion
- Served as member of the Tax Drafting Group for FERC's Standard Generator Interconnection and Operation Agreement
- Obtained from the IRS the first-ever private letter rulings classifying a Texas limited liability company, a Polish limited liability company and a Russian joint enterprise as partnerships for federal income tax purposes
|
| Results depend upon the facts of each case. |
|
Activities and Affiliations
- President: International Tax Forum of Houston
- Vice President: International Fiscal Association USA Branch
- Fellow: American College of Tax Counsel
- Former Chair: Committee on U.S. Activities of Foreigners and Tax Treaties, Section of Taxation, American Bar Association; International Tax Committee, State Bar of Texas
- Former President: Section of Taxation, Houston Bar Association
- Member: Section of Taxation, American, Texas, and Houston Bar Associations
- Member of Advisory Board: Journal of Taxation of Global Transactions
- United States Reporter: International Fiscal Association's Congresses in Sydney, Australia on taxation of the extractive industries, and in Barcelona, Spain on confidentiality in tax matters
- Former Adjunct Professor: U.S. foreign tax credit, University of Houston Law Center
- Founder: State Bar of Texas International Tax Institute, Dallas, Texas
- Governing Director: The Houston Symphony
- Former Director: Chapelwood United Methodist Church
- Listed: The International Who's Who of Business Lawyers in corporate tax law, 2006; Chambers Global: The World's Leading Lawyers in tax law, 2005-2007; Chambers USA: America's Leading Business Lawyers in tax law, 2003-2006; Who's Who in America; International Who's Who of Corporate Tax Lawyers; The Best Lawyers in America in tax law, 1989-2006; "Texas Super Lawyer" in tax law, Texas Monthly, 2004-2005; Euromoney Guide to the World's Leading Tax Lawyers; Euromoney Guide to the Leading U.S. Tax Lawyers; "The Best Lawyers in Houston," H Texas, 2004; "2005 World Tax Review" leading lawyer, International Tax Review, 2005
- Author: "Using the Brown Group Regulations to Minimize Subpart F Income," Journal of Taxation of Corporate Transactions, Summer 2003; "Basic U.S. Tax Considerations in Buying or Selling a Non-U.S. Business," Tax Notes International, May 12, 2003, Tax Notes, June 2, 2003; "International Joint Ventures: Basic Tax Goals and Structures," Tax Notes, April 23, 2001, Tax Notes International, April 30, 2001; numerous articles on various aspects of tax law and practice in leading tax journals
- Lecturer: American Law Institute/American Bar Association courses; Practicing Law Institute programs; Tax Executives Institute; World Trade Institute Seminars; Southwestern Legal Foundation and State Bar of Texas Continuing Legal Education programs
- Speeches: "U.S. Tax Considerations in Buying or Selling a Non-U.S. Business," June 17, 2003 and February 27, 2003; "Structuring International Operations," June 19, 2001; "International Joint Ventures: Tax Goals and Structures," International Fiscal Association, February 22, 2001; "U.S. Tax Considerations in Buying or Selling a Non-U.S. Business," January 31, 2001; "Cómo Hacer Negocios Con Tejas," Chamber of Commerce, Monterrey, Mexico; "U.S. Tax Considerations in Buying or Selling a Foreign Business," "Current Developments in the Use of Partnerships in International Transactions," Tax Executives Institute; "International Joint Ventures and Hybrid Entities," World Trade Institute
|
|
Education and Professional Background
- Northwestern University, B.A., 1963; J.D., cum laude, 1966
- Southern Methodist University, LL.M. in Taxation, 1972
- Admitted to practice: Texas, 1966; Illinois, 1966
|
|
|
|
|
