- Federal Tax
- Capital Markets & Investments
- Private Capital
- Private Equity
- Mutual Funds
- Mergers & Acquisitions
- Business Development Companies
- Venture Capital & Early Stage Finance
- Private Investment Funds
- Tax Controversy & Litigation
|Contact Info||Telephone: 202.383.0137|
|University ||Florida State University, B.S., cum laude|
|Law School||University of Georgia School of Law, J.D., cum laude Member, Georgia Law Review, Order of the Coif; University of Florida Levin College of Law, LL.M.|
|Admitted||District of Columbia; U.S. Tax Court; Georgia, Inactive; Florida|
Member, Partnership and LLC Committee, Taxation Section, American Bar Association
Member, Taxation Section, District of Columbia Bar
|Born||Brookings, South Dakota, January 3, 1968|
With more than 15 years of experience, David Roby provides federal tax advice to national and multinational companies and partnerships concerning a wide variety partnership, corporate and consolidated return issues. He regularly advises clients on the federal tax aspects of sales and acquisitions, mergers and other corporate reorganizations, spin-offs, internal restructurings and leasing transactions. In addition, he provides advice with respect to the structuring and operation of domestic and international partnerships, limited liability companies and other joint ventures. David also advises start-up companies on choice-of-entity and other business structuring issues.
David's practice includes a particular focus on providing solutions to the federal tax matters and problems faced by public and private investment companies and funds in their complex financial transactions. His clients include regulated investment companies (RICs), business development companies (BDCs), hedge funds, private equity funds, venture capital funds, real estate investment funds and real estate investment trusts (REITs).
David began his legal career with a clerkship in the U.S. Tax Court, and he has experience in all aspects of federal tax controversy and litigation. His practice before the Internal Revenue Service (IRS) includes providing advice on audits and appeals, drafting protests and ruling requests, and negotiating settlements. As a litigator, he advises on cases in tax court and federal district and appellate courts.
Sutherland assists clients on structuring, documenting debt and equity offerings for BDCs and closed-end funds.
Sutherland represents Eagle Energy Partners in its sale to Lehman Brothers Commodities Holdings.
Sutherland represents Fifth Street Finance in $140 million IPO.
Honorable Carolyn P. Chiechi, U.S. Tax Court.
Documents by this lawyer on Martindale.com
IRS Targets Use of Basket Option Contracts and Basket Contracts by Hedge Funds and Other Taxpayers as Tax Avoidance Transactions
Robert S. Chase,Daniel R.B. Nicholas,David A. Roby,Rich Sun,Carol P. Tello, July 16, 2015
On July 8, the Internal Revenue Service (IRS) issued two notices (Notice 2015-47, 2015-30 IRB 1, and Notice 2015-48, 2015-30 IRB 1) targeting the use of Basket Option Contracts and Basket Contracts as tax avoidance transactions or possible tax avoidance transactions. Similar transactions have...
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