Clients call on Mike for this depth of experience in complex tax matters. For more than a decade, he has focused on tax planning and structuring for both publicly and privately held entities. He has advised clients with respect to cross-border tax issues, structuring of mergers, acquisitions and dispositions, securities disclosures, corporate and partnership formation and restructuring, bankruptcy and insolvency, private equity and venture capital transactions, and tax exempt organization formation and compliance.
As a part of his transactional practice, Mike often advises clients with respect to issues involving executive compensation planning, including non-qualified deferred compensation arrangements, severance plans, split-dollar life insurance arrangements and Internal Revenue Code Section 409A compliance.
Mike also has substantial experience advocating for clients in matters adverse to the Internal Revenue Service and the North Carolina Department of Revenue, and has successfully obtained private letter rulings from the Internal Revenue Service on behalf of clients.
In addition to his tax practice, Mike assists clients with both tax and non-tax legislative and regulatory interpretation and drafting to assist clients in their planning, public affairs and lobbying efforts.
Any result the lawyer or law firm may have achieved on behalf of clients in other matters does not necessarily indicate similar results can be obtained for other clients.
- Successfully represented Home Concrete & Supply, LLC before the Fourth Circuit Court of Appeals (Home Concrete & Supply, LLC, et. al v. United States, 634 F.3d 249 (4th Cir. 2011)) and the United States Supreme Court (United States v. Home Concrete & Supply, LLC, et. al, 566 U.S. 478 (2012)) in a case in which the Supreme Court upheld the three-year statute of limitations on tax assessments and ruled that treasury regulations promulgated by the US Treasury were invalid under the principles of Chevron, USA v. National Resources Defense Council, Inc., 467 US 837 (1984).
- Consolidated and restructured the multiple businesses of a mid-sized logistics company to provide flow through taxation under a newly formed ESOP for the benefit of the company’s employees and founding owners.
- Negotiated side letter tax provisions on behalf of a large government-controlled pension fund with respect to investments in both domestic and offshore venture funds, private equity funds and hedge funds.
- Obtained private letter ruling from the Internal Revenue Service clarifying complex tax issues relating to an exchange of over $3 billion of old public debt for new public debt for a large public company client in connection with its acquisition of a competitor.
- Devised multifaceted partnership restructuring with new debt and equity investment as well as restructured management equity incentive plan for a national integrative marketing company client.