Randy Buchanan is a member of Sutherland's Tax Practice Group, where he practices exclusively in the area of federal taxation, with an emphasis on transactions with international tax implications. Randy is experienced in analyzing and structuring transactions and planning opportunities, including acquisitions, dispositions, reorganizations, joint ventures, restructurings, Subpart F planning, repatriation techniques and financial transactions. This experience includes the structuring of intercompany indebtedness and international finance and hedging centers. His practice also has included tax accounting issues and issues relating to hedging transactions. Randy has extensive experience with respect to foreign currency issues involving U.S. tax reporting of foreign operations as well as foreign currency transactions, including in the context of hyperinflationary economies. Representative Experience Representative matters illustrating Randy's extensive experience include the following: · Representing Kraft as tax counsel in its acquisition of Cadbury, valued at approximately $19 billion (2010). · Represented Altria as tax counsel in its acquisition of UST, valued at approximately $11.7 billion (2009). · Represented 3M as tax counsel in its approximately $1.2 billion acquisition of Aearo (2008). · Represented Altria as tax counsel in Altria's spin-off of Philip Morris International Inc., one of the largest spin-offs to date, valued at approximately $113 billion (2008). · Represented 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). · Represented Philip Morris International as tax counsel in its approximately $2 billion acquisition of Rothmans Canada (2008). · Represented Altria as tax counsel in its approximately $50 billion spin-off of Kraft (2007). · Represented Kraft as tax counsel in its purchase of Group Danone's global biscuit business for approximately $7.6 billion (2007). · Represented Philip Morris International as tax counsel in its acquisition of an increased stake in its Mexican tobacco business for approximately $1.1 billion (2007). · Represented Philip Morris International as tax counsel in its approximately $5 billion acquisition of PT HM Sampoerna Tbk, an Indonesian cigarette company (2005). · Represented Altria as tax counsel in its approximately $5.6 billion sale of Miller Brewing Company to South African Breweries PLC (2002). · Represented Altria and Kraft in the acquisition of Nabisco for approximately $15 billion in 2000 and the subsequent offering of more than $8 billion of Kraft stock in 2001 in the second-largest IPO ever undertaken. Professional Honors and Awards · Recognized by The Legal 500 United States in the area of tax: international (2011) Professional and Community Involvement · Member, American Bar Association · Member, Section on Taxation, District of Columbia Bar Recent Publications and Speaking Engagements · Author, "Tax Aspects of Foreign Currency," Tax Management Portfolio No. 921 (2002) · Speaker, TEI European Chapter Winter Conference (January 28-29, 2008) News Sutherland Makes Mark in The Legal 500 for 2011
December 1, 2011 The Dealmakers
April 10 -16, 2009 Reprinted with permission Atlanta Business Chronicle Legal Alerts Legal Alert: American Jobs Creation Act of 2004
October 25, 2004 Publications Tax Aspects of Foreign Currency
2002, Tax Management Portfolio No. 921 Events TEI European Chapter Winter Conference
January 28-29, 2008 |