Aaron Payne is a member of Sutherland's Tax Practice Group focusing in the areas of federal taxation, corporate taxation, and international tax planning and transactions.
Aaron has experience analyzing and structuring transactions including domestic and international mergers, acquisitions, and reorganizations, and has participated in advising clients regarding subpart F planning, repatriation techniques and foreign currency transactions
Representative Experience
Aaron's recent representative experience includes:
· Representing Kraft as tax counsel in its acquisition of Cadbury, valued at approximately $19 billion (2010).
· Representing Kraft as tax counsel in its approximately $2.6 billion tax-free split-off of its Post cereals business and the merger of the Post cereals business into a subsidiary of Ralcorp Holdings (2008).
Professional and Community Involvement
· Member, American Bar Association
· Member, Section of Taxation, District of Columbia Bar
Publications
· Co-author, "You Can't Spell 'Subchapter C' Without E&P: Proposed Treasury Regulations Clarify the Rules Concerning the Allocation of Earnings and Profits in Tax-Free Transfers," BNA Insights (Federal)- Bloomberg BNA Tax and Accounting Center (April 2012)
News
You Can't Spell "Subchapter C" Without E&P: Proposed Treasury Regulations Clarify the Rules Concerning the Allocation of Earnings and Profits in Tax-Free Transfers
April 2012
Legal Alerts
Legal Alert: You Can't Spell "Subchapter C" Without E&P: Proposed Treasury Regulations Clarify the Rules Concerning the Allocation of Earnings and Profits in Tax-Free Transfers
April 17, 2012
Legal Alert: Eighth Circuit Affirms Denial of Class Certification in Fixed Annuity Interest Crediting Case
August 30, 2010
Legal Alert: IRS Issues Welcome Guidance Regarding Treatment of Releases of Property Securing REMIC Loans
August 26, 2010