Lynn Fowler focuses his practice on corporate and business tax law. He specializes in helping clients develop and implement tax-efficient strategies for varied business formation, financing, operations, and disposition transactions. Mr. Fowler has significant experience in advising clients to qualify for a variety of federal income tax credits. He has also been the lead tax advisor on numerous taxable and tax-free M&A transactions as well as a variety of other strategic corporate transactions. He serves as Chair of the firm's Tax team. Mr. Fowler was listed in the 2011 and the two years immediately preceding editions of Chambers USA: America's Leading Lawyers for Business and Georgia Trend's "Legal Elite" for Taxes, Estates & Trusts in 2009, 2010 and 2011. He was listed in The Best Lawyers in America® for Tax Law in 2011 and 2012. He was recognized as a Georgia "Super Lawyer" by SuperLawyers magazine in 2011 and the two years immediately preceding. He is AV® rated by Martindale-Hubbell. Professional & Community Activities American Civil Liberties Union Foundation, Board of Directors American Bar Association, Taxation Section, Committee on Partnership Taxation, Member Atlanta Tax Forum, Member Planned Parenthood Southeast, Board of Directors State Bar of Georgia, Taxation Section, Member University of Georgia School of Law, Adjunct Professor Industries Technology & Software; Health Care; Real Estate Experience Division sale for Goodrich Corporation, Represented Goodrich Corporation, which supplies systems and services to the aerospace and defense markets, in sale of ATS Division to Macquarrie Group Limited. Strategic acquisition for Equifax, Inc., Represented Equifax, Inc., one of the United States' largest credit reporting agencies, in its $1.4 billion acquisition of publicly held TALX corporation for a combination of stock and cash. The transaction was structured as a tax-free reorganization with a unique share buy back structure to prevent share dilution. Business combination of Certegy Inc. and Fidelity National Information Services Inc., Represented Certegy Inc., a major publicly held credit card and check verification company, in its $4.5 billion merger with Fidelity National Information Services Inc. and related special dividend to shareholders. The firm also advised the company on issues regarding executive compensation and employee benefits matters relating to the merger. Integration of Atlanta Cardiology Group P.C. into Piedmont Heart Institute, a subsidiary of the Piedmont Healthcare System, Represented Atlanta Cardiology Group P.C. with its integration from a large multi-office cardiology practice into Piedmont Heart Institute. Representation included sale of practice assets, the sale of the practice's interest in CSA of Atlanta U.S., a cath lab joint venture, and long-term employment agreements with physicians to Piedmont Health Institute. Sale of pathology laboratory, Represented seller in the sale of pathology laboratory through the sale of shares following spinoff of anatomic laboratory to shareholder. Global License, Development and Commercialization agreement for Biotest AG, Served as lead counsel in representing Biotest AG (Biotest), a German publicly traded biotechnology company, in signing a global License, Development and Commercialization Agreement with Abbott Laboratories for the further development and commercialization of Biotest's BT-061, a novel anti-CD4 antibody for the treatment of Rheumatoid Arthritis (RA) and psoriasis. In connection with the deal, Biotest will receive an upfront payment of $85 million, and upon completion of certain milestones, additional payments totaling $395 million, plus royalties. Formation of real estate investment funds for real estate investment, development and finance company, Represented a real estate investment, development and finance company in the formation and securities offering of six real estate investment funds. Private placement of real estate opportunity fund for Wells Real Estate, Represent Wells Real Estate in private placement of real estate opportunity fund. IRS challenging a listed transaction for a global manufacturer, Represented a global manufacturer in a case involving a highly controversial "listed transaction" being challenged by the IRS. The listed transaction at issue, which initially was undertaken by many corporate taxpayers, involved the client claiming deductions for contributions to its 401k plans prior to the year that employees performed the services giving rise to the contributions. While the weight of authority supported this deduction in the taxpayer's circumstances, the IRS challenged the deduction, labeling it abusive. The team filed a Motion for Partial Summary Judgment, asking the Tax Court to dismiss the IRS's proposed deficiencies relating to the 401k deductions. The IRS agreed to concede the case, dropping its proposed assessments of tax and penalties exceeding $25 million. Venture capital and investment fund matters for Wells Real Estate, Represent Wells Real Estate in venture capital and investment fund matters. *Experience gained by attorney prior to joining Kilpatrick Townsend Publications 23 August 2010, Complex Tax Planning and Penalties after Canal: Independence of Tax Advice is the Key, Legal Alerts 21 June 2010, IRS Commences Therapeutic Discovery Project Credit Application Process, Legal Alerts 27 May 2010, Treasury's Qualifying Therapeutic Discovery Project Credit Program Provides Short Window For Application, Legal Alerts 14 May 2010, Congress Adds New Investment Tax Credit for Qualified Therapeutic Drug Products, Legal Alerts 04 March 2010, IRS Employment Tax Audits Take Center Stage, Legal Alerts 01 August 2009, Publicly Traded Partnerships
Source: Publicly Traded Partnerships, Practising Law Institute, Tax Planning for Domestic, Other Publications 01 August 2009, Selected Tax Issues of Private Investment Funds
Source: Publicly Traded Partnerships, Practising Law Institute, Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, Other Publications 13 March 2009, Stimulus Legislation Provides Tax Relief for Certain Debt Restructurings, Legal Alerts 26 February 2009, Stimulus Legislation Provides Targeted Benefit for Certain S Corporations, Legal Alerts 01 January 2009, Taxation of Intellectual Property
Source: Intellectual Property Desk Reference, Other Publications 01 October 2008, IRS Clarifies Treatment of Bank Bad Debts After Ownership Change, Legal Alerts 23 May 2008, Another Tax Workpaper Victory, Legal Alerts 22 June 2007, House Proposes Radical Change in the Taxation of Partnership Carried Interests, Legal Alerts 06 September 2006, Legal Alert Detail PageAppeals Court Holds Taxation of Damage Awards for Nonphysical Injuries Unconstitutional, Legal Alerts News 15 December 2011, Kilpatrick Townsend Attorneys Named 2011 "Legal Elite", News Releases 06 September 2011, Kilpatrick Townsend Earns Record-Breaking Recognition in Annual Best Lawyers in America 2012, News Releases 21 June 2011, Kilpatrick Townsend Plays Role in Abbott and Biotest Global Agreement, News Releases 13 June 2011, Kilpatrick Townsend Again Earns Highest Recognition From CHAMBERS USA 2011, News Releases 02 March 2011, Kilpatrick Townsend Once Again Achieves Top Recognition in 2011 Georgia Super Lawyers, News Releases 13 December 2010, Kilpatrick Stockton Attorneys Named 2010 "Legal Elite", News Releases 12 August 2010, Kilpatrick Stockton Earns Record-Breaking Recognition in Annual Best Lawyers in America 2011, News Releases 14 June 2010, Kilpatrick Stockton Again Earns Highest Recognition From CHAMBERS USA 2010, News Releases 04 March 2010, Kilpatrick Stockton Ranked Number One in Five 2010 Georgia Super Lawyer Categories, News Releases 31 December 2009, Kilpatrick lawyers seal acquisition, In the News 08 December 2009, Kilpatrick Stockton Attorneys Named 2009 "Legal Elite", News Releases 15 June 2009, Kilpatrick Stockton Once Again Earns Highest Recognition From Chambers USA, News Releases 02 March 2009, Kilpatrick Stockton Ranked Number One in Five Georgia Super Lawyer Categories, News Releases Events 13 March 2012, KT Breakfast Briefing - Intellectual Property Tax Planning for Multinational Businesses, Events 01 August 2011, IP Considerations in M&A Transactions, Events 16 June 2011, Troubled Debt, Events (Also at Washington, DC Office) |